Pillar 3 Disclosure report BNG Bank 2017 BNG Bank... · 2018-05-09 · liquidity and operational...

BANK

Pillar 3 Disclosure reportBNG Bank 2017

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Contents

CONTENTS

Preliminary remarks 5

Frequency and means of disclosure (articles 433 and 434 CRR) 6

Risk management objectives and policies (article 435 CRR) 8

General information 8

Credit risk 16

Market risk 23

Liquidity risk and funding risk 28

Operational risk 33

Strategic risk 37

Scope of application (article 436 CRR) 41

Differences between accounting and regulatory scopes of consolidation and mapping of financial categories to regulatory risk categories (EU LI1) 42

Main sources of differences between regulatory exposure amounts and carrying values (EU LI2) 45

Explanations of differences between accounting and regulatory exposure (EU LIA) 47

Outline of the differences in the scopes of consolidation (EU LI3) 48

Own funds (article 437 CRR) 49

Balance Sheet Reconciliation 49

Capital instruments’ main features template 53

Transitional own funds disclosure template 56

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Capital requirements (article 438 CRR) 69

Capital and Solvency 69

Overview of RWA (EU OV1) 73

Credit risk and credit risk mitigation (article 442 en 453 CCR) 76

Credit quality assets 77

Total and average net amount of exposures (EU CRB-B) 79

Geographical breakdown of exposures (EU CRB-C) 80

Concentration of exposures by industry or counterparty types (EU CRB-D) 82

Maturity of exposures (EU CRB-E) 84

Credit quality of exposures by exposure classes and instruments (EU CR1-A) 86

Credit quality of exposures by industry or counterparty types (EU CR1-B) 89

Credit quality of exposures by geography (EU CR1-C) 90

Ageing of past-due exposures (EU CR1-D) 91

Non-performing and forborne exposures (EU CR1-E) 92

Changes in stock of general and specific credit risk adjustments (EU CR2-A) 94

Changes in stock of defaulted and impaired loans and debt securities (EU CR2-B) 95

Credit risk mitigation techniques – overview (EU CR3) 96

Standardised approach – credit risk exposure and Credit Risk Mitigation (CRM) effects (EU CR4) 97

Standardised approach before risk mitigation (EU CR5) 99

Counterparty credit risk (article 439 CRR) 101

Analysis of the counterparty credit risk (CCR) exposure by approach (EU CCR1) 101

Credit valuation adjustment (CVA) capital charge (EU CCR2) 103

Standardised approach – CCR exposures by regulatory portfolio and risk (EU CCR3) 104

Impact of netting and collateral held on exposure values (EU CCR5-A) 105

Composition of collateral for exposures to counterparty credit risk (EU CCR5-B) 106

Exposures to central counterparties (EU CCR8) 107

CONTENTS

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Unencumbered assets (article 443 CRR) 108

Encumbered and unencumbered financial assets 108

Collateral received by an institution, by broad categories of product type 109

Carrying amount of encumbered assets/collateral received and associated liabilities 110

Narrative information on the importance of asset encumbrance for an institution 111

Market risk (article 445 CRR) 112

Market risk under the standardised approach (EU MR1) 112

Remuneration (article 450 CRR) 113

Leverage ratio (article 451 CRR) 116

Exposures in equities not included in the trading book (article 447 CRR) 120

Exposure to securitisation positions (article 449 CRR) 122

Mapping of regulatory requirements 124

CONTENTS

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Preliminary remarks

The current international regulatory framework for banks consists of a comprehensive set of measures developed by the Basel Committee on Banking Supervision (known as Basel III). Basel III has been implemented in the European Union through the Capital Requirements Directive IV (CRD IV) and is applicable as of January 1st 2014. CRD IV is formed by two legal acts (a Directive and a Regulation) and includes various transitional provisions which allow for a gradual phasing in of the new requirements.

The Basel framework (and thus CRD IV) is based upon three pillars:– The first pillar consists of minimum capital requirements for three main categories of risk:

credit risk, market risk and operational risk.– The second pillar provides a framework for banks to review their capital (and liquidity)

adequacy for both the risks identified in Pillar 1 as well as all other risks (e.g. concentration risk, strategic risk, etc.). This internal review by banks is known as the Internal Capital/Liquidity Adequacy Assessment Process (ICAAP/ILAAP). Supervisors independently assess these processes in their Supervisory Review and Evaluation Process (SREP).

– Finally the third pillar aims to introduce market discipline to complement the capital and liquidity requirements from the first and second pillar. Therefore Basel III (and CRD IV) contains a set of disclosure requirements which will allow market participants to have a sufficient understanding of a bank’s activities, the risks that are involved and the controls that are implemented to manage these risks.

This report is drafted in response to the last pillar. The Pillar 3 disclosure provides a comprehensive overview of the risk profile of BNG Bank. Central to the Pillar 3 disclosure requirements is to promote the transparency of financial institutions and provide market participants with an adequate and comparable picture of the risks of a financial institution. This contributes to a proper functioning of financial markets, improves efficiency of market discipline and helps in building trust between market participants.

PRELIMINARY REMARKS

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Frequency and means of disclosure (articles 433 CRR

and 434 CRR)

The Pillar 3 disclosure of BNG Bank is published annually. This Pillar 3 Report is published on the website of BNG Bank shortly after the publication of the Annual Report.

In previous years the Pillar 3 Disclosure report mainly served as a reference guide to clearly indicate where relevant information could be found in the financial statements. However, as of 31 December 2017 the EBA guidelines on diclosure requirements1 are applicable to the disclosure of financial insitutions (as defined in Artilcle 4(1) of Regulation (EU) No 1093/2010). These guidelines prescribe in detail the tables and templates through which the Pillar 3 information needs to be disclosed.

These tables and templates do not fully align with the information that is disclosed in the financial statements of BNG Bank as these statements are based on IFRS accounting principles. Therefore, this year a Pillar 3 Disclosure report has been drafted that contains the required Pillar 3 information separately and can be read on its own. On the other hand, a part of the information is already included in the financial statements. This is especially true for the qualitative information in the risk section of the financial statements. This information is reproduced in this report.

In this respect the report can be divided in two parts. The first section provides a comprehensive qualitative overview on the management of risks by BNG Bank and is derived mostly from the risk section of the financial statements. Where possible quantitative information from this risk section is, however, omitted as the second part of this report contains all templates for disclosing the relevant quantitative information as provided for by the European Banking Authority (EBA)2. The order of these different sections has been aligned with those EBA guidelines and standards. For the sake of completeness, the last section includes a overview of the regulatory requirements regarding Pillar 3 disclosure and the location where the information can be found.

FREQUENCY AND MEANS OF

DISCLOSURE (ARTICLES 433 AND

434 CRR)

1 EBA/GL/2016/11, Guidelines on disclosure requirements under Part Eight of Regulation (EU) No 575/20132 Templates and tables are described in detail in EBA/GL/2016/11, Guidelines on disclosure requirements under Part Eight of

Regulation (EU) No 575/2013

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Following relevant EBA guidelines on the frequency of disclosure3 BNG Bank has assessed the need to publish information more frequently than annually. An annual publication of a comprehensive Pillar 3 disclosure report is deemed sufficient despite the designation of BNG Bank as an other systemically important institution (O-SII). BNG Bank is characterized by a stable business model with a limited range of activities and exposures. The resulting risk profile of BNG Bank is not prone to any rapid changes. And in general, the information, that would qualify for more frequent disclosure, does normally not exhibit any sudden changes either. An annual disclosure suffices therefore.

In addition, BNG Bank does publish an interim report on its website which is reviewed by an external auditor. Any sudden changes in the financial position or in the markets in which BNG Bank operates will be addressed in this interim report. If these circumstances would lead to material changes in the risk profile of BNG Bank an additional disclosure of some or all of the Pillar 3 requirements will be contemplated.

Finally, it should be noted that information in this report has not been audited. However, the appropriateness of the disclosed information is approved by the Executive Board of BNG Bank. Information that is considered to be proprietary or confidential will not be published, but is disclosed in a more general manner. The Annual Report itself is audited by an external auditor.

3 EBA/GL/2014/14, Guidelines on materiality, proprietary and confidentiality and on disclosure frequency under Articles

432(1), 432(2) and 433 of the CRR

FREQUENCY AND MEANS OF

DISCLOSURE (ARTICLES 433 AND

434 CRR)

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General information

INSTITUTION RISK MANAGEMENT APPROACH The process of accepting and controlling risks is inherent to the day-to-day operations of any bank. In order to conduct its operations, a bank must accept a certain amount of credit, market, liquidity and operational risk. On top of this, there is strategic risk. BNG Bank only has a banking book and does not have a trading book. BNG Bank’s risk management strategy is aimed at maintaining its safe risk profile, which is expressed in its high external credit ratings. For this reason, BNG Bank employs a strict capitalisation policy.

RISK APPETITE STATEMENTThe bank has prepared a Risk Appetite Statement (RAS) describing its risk appetite, which sets out the types and degree of risk the bank is willing to assume, decided in advance and within its risk capacity, to achieve its strategic objectives and business plan. The risk appetite falls within the risk capacity, which is the maximum risk level that the bank is able to assume given its capital base, risk management and control capabilities as well as its regulatory constraints and at which the bank is still able to meet its obligations towards its clients, investors, shareholders and other stakeholders. The bank has a mission, a strategy and core values, which jointly influence the risk culture. The bank balances the interests of the various stakeholders when fulfilling the mission and executing the strategy. To facilitate this, a stakeholders model is used which is represented in the next figure.

GENERAL INFORMATIONRISK MANAGEMENT OBJECTIVES

AND POLICIES (ARTICLE 435 CRR)

Risk management objectives and policies (article 435 CRR)

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Formulating a risk appetite also requires definitions of risks to ensure everyone speaks the same language. BNG Bank recognises the financial risks of credit risk, market risk and liquidity risk, as well as the non-financial risks of operational risk and strategic risk in this regard. Finally, several components are defined that form the core of the bank’s operations and constitute the framework within which the risk appetite is formulated. In the case of a bank, the components (1) Profitability, (2) Solvency and (3) Liquidity are most obvious. These are widely used concepts for assessing the security and hence the risk profile of a bank. Besides those components, BNG Bank has also opted for (4) Reputation and Brand as BNG Bank has always placed great value on an impeccable reputation. The risk appetite is evaluated annually and adjusted where necessary in order to ensure that it remains in line with BNG Bank’s strategic objectives:– substantial market shares in the Dutch public sector and semi-public domain;– generate a reasonable return for its shareholders.

And satisfies the conditions identified in this context:– an excellent credit rating and adequate risk management;– an excellent funding position;– effective and efficient operations.

In translating these strategic objectives and conditions into the risk appetite, the bank identifies the interests and expectations of all its stakeholders. This subsequently results in the formulation of objectives with regard to profitability, solvency, liquidity and reputation & brand in the form of the RAS. The RAS is laid down by both the Executive Board and the Supervisory Board. Once the risk appetite has been established, it is translated to the different risks, namely the financial risks of credit risk, market risk and liquidity risk, and the non-financial risks of operational risk and strategic risk.

PROFITABILITY SOLVENCY LIQUIDITY

COMPONENTS

REPUTATION & BRAND

MISSION, STRATEGY, RISK CULTURE

RISK APPETITEFRAMEWORK

EXPECTATIONS & INTERESTS

STAKEHOLDERS

SHAREHOLDERS

INVESTORS

CLIENTS

FINANCIAL COUNTERPARTIES

GOVERNMENT

EMPLOYEES

SUPERVISORY AUTHORITIES

RATING AGENCIES

RISKS

CREDIT RISK

MARKET RISK

LIQUIDITY RISK

OPERATIONAL RISK

STRATEGIC RISK



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PROFITABILITY

BNG Bank aims to minimise charges for the public sector, and hence does not seek to maximise profits. For its shareholders the

bank’s objective is to achieve a reasonable return. Relative stability of the annual results is also important to different stakeholders,

including regulatory authorities and rating agencies. ‘Relative’ in this context refers to a maximum percentage of deviation relative

to the previous annual result.

SOLVENCY

BNG Bank aims expressly to stand out in the financial markets in terms of the size and quality of its capital. This is expressed in the

desired rating profile: a rating at the same level as that of the Dutch State. To realise this, BNG Bank’s capital must be significantly

greater than the criteria applied by the regulatory authorities and significantly greater than (the majority of) other banks to ensure

favourable funding rates. This relates to domestic Dutch banks as well as foreign banks.

LIQUIDITY

BNG Bank intends to use its position to maintain a lasting and stable presence in the market for the public sector and continue to

meet the demand for lending even in difficult times. It also aims for a prudent liquidity position, with due regard for the principles

that it is always able to meet its short-term obligations and also adequately mitigates its refinancing risk. In this context, continuous

access to funding is crucial and hence continuous maintenance of an attractive, varied issuance programme of sufficient volume for

investors. In addition, it is important to have sufficient collateral lodged with the ECB to ensure short-term funding can be raised

with the ECB in times of need.

REPUTATION & BRAND

BNG Bank aims to retain the perception its stakeholders have of it as a quasi-public sector body, with excellent creditworthiness

and a fine reputation and integrity profile. The bank wants to retain the status of promotional bank. The nature and size of financial

losses should be aligned with the perception of its stakeholders and not include any unexpected elements. The bank is not willing

to assume any risks for which it may reasonably be presumed that the risk can harm its integrity and/or reputation. BNG Bank

aims to exercise due care in the provision of services and to observe a duty of care towards its clients, and endeavours to provide

tailored products and services at competitive rates.

The risk appetite for the four components is reflected in the following objectives:

RISKS ACCEPTED BY BNG BANKIn order to achieve its goals, the bank has identified the types of risks it is prepared to accept as a consequence of its strategy and business operations. Three important principles in this respect are: – BNG Bank aims to provide the best possible services to its stakeholders, now and in the future.

The return required by its principal shareholder takes account of the bank’s risk profile. This means that the required return should not result in the bank taking such considerable risk as to jeopardise its ratings and funding position, as a consequence of which it would no longer be able to fulfil its mission in the long term. Subject to certain conditions, the bank seeks a higher return than this external return requirement.

– In addition to a reasonable return for shareholders, low prices are the major focus. BNG Bank is willing to assume the necessary risks, in a controlled manner, that go hand in hand with lending to clients. The bank is furthermore willing to assume certain additional risks for activities that support lending to clients. Achieving an additional return (based on considerations of risk and return) makes lower prices for clients possible now and in the



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future. Again, this may not be at the expense of the external ratings and excellent funding position, since that would jeopardise the bank’s mission.

– In the public sector there is a distinction between lending not subject to solvency requirements (zero risk weighted) and lending that is subject to solvency requirements (non zero risk weighted), whether this is caused by guarantees or otherwise. The largest share of the bank’s lending (loans and advances) is not subject to solvency requirements. In order to facilitate this lending at the lowest possible rates, it is essential that the bank retains its competitive funding position. This in turn is dependent on the high ratings, forcing the bank to impose restrictions on lending subject to solvency requirements, in view of the related credit risks.

As a result of the foregoing, the bank is prepared to accept the following risks.

CREDIT RISK– Counterparty risk associated with lending subject to solvency requirements to clients.

Certain non solvency free parties belong to the public sector and hence are covered by the bank’s mission. Additionally, the return on lending subject to solvency requirements can support the competitive rates charged for lending not subject to solvency requirements.

– Risks in terms of financial counterparties associated with activities that support lending (including the hedging of market risks through derivatives).

– Concentration risk in relation to the Dutch public sector is inherent to the business model. A sizeable part of the associated exposure relates to public sector real estate. For the most part, this risk is mitigated by the guarantee funds in the Social Housing sector and Healthcare sector, resulting ultimately in a risk exposure to the Dutch State.

– Investments that support lending to clients.

MARKET RISK– BNG Bank hedges the interest rate risks arising from lending (loans and advances) and

borrowing. However, the bank is willing to assume a certain degree of interest rate risk. On the one hand, a certain maturity mismatch, related to the bank’s capital base, is a common source of income for banks (longer lending term than borrowing term). Additionally, BNG Bank strives to achieve additional return with an active interest rate position policy. With regard to (tenor) basis risk the bank assumes a limited position arising from regular funding and lending.

– It is the banks policy to hedge any option positions, unless they support the active interest rate position policy.

It should be noted that BNG Bank is not willing to assume any exposures to foreign exchange risk. Foreign exchange risks are therefore hedged, including FX basis risk. Furthermore, BNG Bank has no trading book and, consequently, does not assume any market risk in connection with trading portfolios.

LIQUIDITY RISK– As BNG Bank wishes to meet its payment obligations at all times, short-term liquidity risks

are only assumed if they are matched by sufficient capital buffers capable of meeting these short-term obligations.

– The public sector consists largely of institutions with a long-term investment horizon. This means that assets frequently have long maturities that can run into decades. As BNG Bank is unable to raise funding for these maturities, a funding mismatch is assumed, provided there are sufficient buffers to be able to refinance at acceptable cost with a high degree of



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probability also in times of stress. The Bank is also willing to assume the refinancing risk arising from the liquidity requirement related to activities other than lending to its clients, as is the case with investments. The ensuing additional liquidity requirement may not jeopardize the bank’s mission.

OPERATIONAL RISK– Operational risk is inherent in operating a business. BNG Bank accepts that providing tailored

services entails additional inherent operational risks with regard to standard products.– Operational risks are mitigated by weighing the costs against the economic benefits, except

in case of compliance with legal and regulatory requirements and duty of care and proper conduct issues, where the risks should be minimised.

– In addition to lending, BNG Bank also provides its clients with other products, such as current account and payment transaction services. Clients benefit considerably from this broader range of services, and this also promotes client loyalty to the bank even if it can be argued that payment transaction services do not significantly contribute to minimising public sector financing costs. The bank is willing to assume operational risks also for these additional products, provided they do not jeopardize its mission.

STRATEGIC RISKIn the case of strategic risk it is more difficult to determine the extent to which risks are assumed, since they are driven by external factors in particular and hence are less easily influenced. However, BNG Bank needs to address the risks that emerge from changes in its environment. It is essential that the bank remains relevant for its clients and is therefore responsive to political and social developments. Sustainability e.g. is a major issue for the bank’s clients. A failure to satisfy clients’ expectations can adversely affect the bank’s market position. BNG Bank actively advances the message that it wishes to partner with clients in relation to sustainability. This carries the reputational risk that it will be unable to adequately fulfil this publicly issued commitment.

In a yearly cycle the RAS is updated based on external as well as internal developments. It is subsequently cascaded into these limits, targets and information figures. These are subject to a monitoring program that is conducted each quarter to determine whether the bank is still within the limits of its risk appetite. The outcomes are reported to the Management Board and Supervisory Board as part of the quarterly Risk Report. Examples of further tools to monitor compliance to the risk of the bank are the yearly In Control Statements by senior management and reports by internal and external auditors. In 2017, the bank operated comfortably within its own risk appetite for market risk, credit risk and liquidity risk. With regard to capital, in 2017, the bank achieved the expected legal requirement including an internally desired buffer. With regard to operational risk, the bank remained well within the internal norms for operational incidents. The tools available for monitoring operational risk have been improved and development will continue in 2018. In monitoring its strategic risk the bank decided to follow an approach aimed at systematically examining the most important strategic risks in a qualitative way.



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RISK MANAGEMENT FRAMEWORKSupplementary to its RAS, BNG Bank applies a Risk Management Framework which provides an overarching framework to monitor and develop the system of limits, targets and reference figures that is used to monitor the risks. This framework defines various risk types, sets out the responsibilities and identifies the various documents and policies that describe the acceptance and management of these risks.



CHARTERS SUPERVISORY BOARDAND EXECUTIVE BOARD

FRAMEWORK

ASSESSMENT

RISK POLICIES

OTHER POLICIES

RISK SELF ASSESSMENT PROCESS

CREDIT RISK POLICY PUBLIC FINANCE

PRODUCT APPROVAL POLICY

DISCLOSURE POLICY

ICAAP

CREDIT RISK POLICY FUNDING & TREASURY

STRESS TESTING POLICY

OUTSOURCING POLICY

ILAAP

MARKET RISK & ALM POLICY

MODEL GOVERNANCE POLICY

SHADOW BANKING POLICY

RECOVERY & RESOLUTION

LIQUIDITY & FUNDING RISK POLICY

MODEL VALIDATION POLICY

OPERATIONAL RISK POLICY

RISK MANAGEMENT FRAMEWORK

RISK MANAGEMENT CHARTER

RISK MANAGEMENT FRAMEWORK

RISK DEFINITIONS RISK APPETITE STATEMENT

Risk management activities are included in all parts of the organisation of BNG Bank. Therefore, BNG Bank has taken into account a solid level of segregation of duties and focusses on the robust execution of risk management activities. Furthermore, BNG Bank has several governing bodies and risk committees in which risks are considered at different levels. The following figure provides an overview:

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SUPERVISION

POLICIES AND DECISION MAKING

OPERATIONAL

EXECUTIVE BOARD (all risks, including strategic risk)

ALCO(market risk, liquidity risk)

CREDIT COMMITTEE(credit risk)

MANAGEMENT BOARD(credit risk, operational risk)

FINANCIAL COUNTERPARTY COMMITTEE(credit risk)

INVESTMENT COMMITTEE(credit risk)

CAPITAL POLICIES AND FINANCIAL REGULATION(all risks)

RISK RELATED GOVERNING BODIES

SUPERVISORY BOARD (all risks)

RISK COMMITTEE(all risks)

BNG Bank has a two-tier governance structure consisting of a Supervisory Board and an Executive Board. An up-to-date overview on the members of these Boards as well as their sub-committees is available on the website4 of BNG Bank. Information on the number of directorships, the profile of board members and their duties and responsibilities is also included here. The responsibilities of the Supervisory Board and of the Risk Committee of the Supervisory Board relating to risk management are stated in their charters. The responsibilities of the Executive Board are stated in a charter as well. Effectively the Supervisory Board as well as the Executive Board have the responsibility to ascertain that the bank is and will remain within its risk appetite and take appropriate measures if this is no longer the case. For an overview as of end December 2017 and the corporate governance statement the Annual Report provides a comprehensive overview (pages 63-72 and 84-95)5.

In the Management Board and the Asset & Liability Committee (ALCO), all members of the Executive Board are included. For this reason all decisions made by the Management Board and by ALCO are formal decisions by the Executive Board. Formal decisions are also made in the Executive Board meeting itself. In the context of risk taking this is mostly the case if either an escalation by an operational risk committee or a decision of a strategic nature is at hand. The risk committees that act on an operational level are chaired by a member of the Executive Board. Three of these committees test if the various risk taking activities of the bank are in line

4 For the Executive Board. For the Supervisory Board.5 The Annual report is available at the website.



https://www.bngbank.nl/over-bng-bank/bestuur-en-organisatie/rvb

https://www.bngbank.nl/over-bng-bank/bestuur-en-organisatie/rvc

https://www.bngbank.com/Documents/Investors/Annual%20Report%202017/Annual%20Report%20BNG%20Bank%202017.PDF

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with the policies. The fourth committee, Capital Policy and Financial Regulations Committee, advises the Management Board on the capital policy and the allocation of capital to the bank’s various business units. In addition, the committee advices on the introduction of new regulations concerning solvency and liquidity as well as on technical financial issues. The committees also advise the Management Board and the ALCO on changes in policies. The operational committees have no mandate to approve policy changes themselves.

The following departments support the Executive Board and the committees in implementing risk policy:– The Risk Management department qualifies, quantifies and monitors risks, and reports to the

responsible committees. These risks consist of credit risk, market risk, liquidity risk, operational risk and other risks. The department has a supporting role as regards strategic risk. The department manages the risk policy documents and the Risk Management Framework. The Risk Management Department participates in the internal risk committees as well as in the Risk Committee of the Supervisory Board.

– The Credit Risk Assessment department provides independent assessments and advice on risks relating to credit and review proposals for clients and financial counterparties. It also formulates policies with respect to credit risk. As part of the operational lending process it is represented in the bank’s Credit Committee, the Financial Counterparties Committee and the Investment Committee. This department is also responsible for the bank’s Special Management activities – being the supervision, management and processing of distressed credits.

– The Internal Audit Department (IAD) periodically conducts operational audits in order to evaluate the structure and performance of the bank’s risk management systems and assess compliance with the applicable legislation. The IAD functions as an independent entity within the bank and reports to the Executive Board. The IAD also has a reporting line to the Supervisory Board.

– Where necessary, the Compliance & Integrity department is engaged in connection with conduct-related issues. This department monitors compliance with all relevant laws and regulations. The duties, position and authorities of this compliance function are laid down in the BNG Bank Compliance Charter. The Compliane officer reports to the Executive Board and has a reporting line to the Supervisory Board.

The Capital Management department also reports directly to the Executive Board. Apart from managing capital policy and allocation the department also actively monitors and analyses upcoming legislative changes.



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Credit risk

DEFINITIONS Credit risk is defined as the chance of losses if and when a counterparty is unable to meet its financial and/or other obligations and includes settlement risk, counterparty risk and concentration risk.– Counterparty risk: The risk of losses if a party fails to make payments that result from a

financial transaction, at the moment those payments are due.– Concentration risk: The overall spread of a bank’s exposures over the number or variety of

debtors to whom the bank has lent money.– Settlement risk: The risk that one party will fail to deliver the terms of a contract (or a group

of contracts) with another party at the time of settlement.

GOVERNANCEBNG Bank has an internal risk management organisation that serves to control its credit risks. This organisation is in line with the diversity and complexity of the bank’s lending activities and is structured as follows:– The Executive Board determines the relevant lending parameters and policies, facilitated

by the Management Board.– The Credit Committee decides on loans and advances subject to solvency requirements.

In some cases, this authority is delegated.– The Financial Counterparties Committee decides on limits for transactions with financial

institutions.– The Investment Committee decides on proposals for investment in interest-bearing securities.– The Client Acceptance Committee assesses whether potential clients are suitable under the

bank’s Articles of Association, whether they fit in the bank’s commercial policy and whether they constitute an integrity risk.

The Credit Risk Assessment department and the Risk Management department (at portfolio level) are responsible for assessing, quantifying and reporting the credit risk. In the organisation, these departments operate independently from the Public Finance and Treasury directorates, which are responsible for contracts that include credit risk. The Risk Management department is internally responsible for all Credit Risk policies.

DEVELOPMENTSBecause of IFRS 9, financial institutions needed to develop an impairment model in order to recognize credit losses before an actual credit event occurs. The impairment model is based on a three-stage process which is intended to reflect deterioration in credit risk. BNG Bank assumes that the credit risk on a financial asset has not increased significantly since initial recognition if

CREDIT RISKRISK MANAGEMENT OBJECTIVES


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the asset is determined to have low credit risk at the reporting date. In that case, the bank measures impairment under 12-month expected credit losses (ECL). Otherwise, the ECL of an asset is either determined on a 12-month or lifetime basis depending on whether a significant increase in credit risk occurred. On top of the existing internal Probability of Default (PD) models, BNG Bank developed an overlay model that calculates an add-on for the PD’s by using forward looking information (FLI) based on forecasts on macroeconomic variables. By incorporating this add-on, the resulting point-in-time PD has a cyclical component. For its internal capital calculations, BNG Bank assigns a Loss Given Default (LGD) percentage to exposures based on values from the Standardized Approach because statistical data is practically unavailable for its client exposures. Since this is not allowed under IFRS 9, an LGD percentage is calculated based on the very little internal and some available relevant external statistical data. The bank applies a cash flow model to calculate the estimated exposure at each future year-end. BNG Bank employs different techniques and judgements in the staging assessment. The techniques or ‘triggers’ differ in nature, being quantitative, qualitative or a backstop indicator. IFRS 9 will be effective as from 1 January 2018.

In 2017 the lean way of working was introduced in the lending process. This led to several organisational changes like working in teams instead of in separate departments. For these organisational changes, separation of duties was monitored by the IAD. The introduction of lean working did not result in significant changes in formal credit risk policies. Any changes in credit risk policies were facilitated by the Risk Management department and approved by the Executive Board.

COUNTERPARTY RISKThe bank is exposed to counterparty risk in relation to public sector entities (loans and advances), financial counterparties (derivatives) and issuers of interest-bearing securities (IBS) in which the bank has invested. BNG Bank applies the following credit risk mitigation measures:– Because loans subject to solvency requirements are often extended under (partial) guarantees

or suretyships, on balance the loan remains (partly) solvency-free for BNG Bank (see the section on statutory market parties). The guarantees are provided by a central or local authority or by the guarantee funds WSW (Social Housing) and WfZ (Healthcare).

– Other forms of security, such as pledges and mortgages are used to minimise possible losses due to credit risks. The potential risk reducing effect, however, is not used in the calculation of the regulatory capital requirement.

– Bilateral netting and collateral agreements based on a daily collateral exchange with financial counterparties. See also the section ‘Financial counterparties’.

STATUTORY MARKET PARTIESThe bank’s Articles of Association limit lending to parties subject to some form of government involvement. As a result, the credit portfolio is largely comprised of solvency-free loans and advances, provided to or guaranteed by the government. In the case of the guarantee funds WSW and WfZ, the credit risk assessment of guaranteed institutions is carried out expressly by the guarantee fund concerned next to the abovementioned assessment by the bank. BNG Bank actively follows the developments within the sectors in which it operates. This also applies to (the operation of) the institutions issuing the individual guarantees or suretyships. In addition, BNG Bank maintains contacts with relevant parties through a variety of channels, including conferences, seminars and bilateral talks. Lending subject to solvency requirements are preceded by an extensive creditworthiness analysis. The responsible team within Public Finance draws up the credit proposal. This contains a detailed assessment of the creditworthiness of the client



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concerned, based in part on the bank’s own internal rating model. The greater the degree of tailoring involved in a transaction, the more intensive the operational risk procedure is followed. To that end, the bank has implemented a tailor-made assessment process in order to keep the complexity manageable for both the client and the bank.– The Credit Risk Assessment department prepares an independent second opinion on the

credit proposal.– The intensity of the decision-making process is determined based on the proposed rating

and the size of the loan. The bank’s risk appetite also determines the level of maximum credit risk the bank is prepared to accept for the client in question. The credit proposal must be in accordance with this maximum risk.

– The Credit Committee decides whether the credit can be accepted. The Credit Committee is chaired by a member of the Executive Board and includes representation from the Public Finance directorate, the Credit Risk Assessment department and – where applicable – the Treasury department. If the Credit Committee is unable to form a unanimous opinion, the decision on the proposal is escalated to the Executive Board. A delegation model applies to loans and advances of limited scale or risk, in which authority to make decisions lies with the Director of Public Finance and the Credit Risk Assessment Manager.

Following the approval of a credit proposal and its acceptance by the client, the credit management process starts. This includes the following elements:– The file is completed with relevant documentation by the Public Finance Teams.– The Public Finance Teams are responsible for the file management, including monitoring

securities and covenants.– The creditworthiness is reviewed at least once a year. This involves an updating of the internal

rating. The Credit Committee evaluates these reviews. A delegation model applies here as well. Loans and advances whose credit quality (rating) has fallen below a specific level (see the table below) are subject to increased management scrutiny and, if necessary, transferred to the Special Management group within the Credit Risk Assessment department.

Despite the virtual absence of credit risk within this solvency-free portfolio, in 2016 the bank has set up an additional process for the assessment and review of the creditworthiness of parties that have only been granted loans and advances that are directly or indirectly guaranteed by the Dutch State. The bank’s internal rating models have been adapted to facilitate these assessments, thus providing consistency with the existing assessment for non solvency free lending. During 2017 these assessments have taken place and a process of fine tuning of policies and processes is in its final stage.

CREDIT MODELSMost of BNG Bank’s clients do not have an external rating. The bank makes their creditworthiness transparent using internally developed rating models. Given the ‘low default’ character of the loan portfolio, expert models are utilised. The models are used for internal assessment of creditworthiness, but not for capital calculations under Pillar I, where the bank uses the Standardised Approach. Models are in use for the following sectors:– Public housing;– Healthcare and Education;– DBFMO (Design Build Finance Maintain Operate, project financing);– Area development;– Financial institutions;– Energy, water, telecom, transport, logistics and the environment.



19

The significance of the internal ratings is the same for all models.

Below table provides an overview of the distribution of the loan portfolio across those ratings. More quantitative details on the credit risk profile and the credit quality is included in the section on credit risk and credit risk mitigation.



INTERNAL RATING DESCRIPTION

0 Solvency-free lending.

1 through 11 The credit risk is deemed acceptable. A regular annual review is performed.

12 through 13 Watch list: there is a heightened credit risk. A review takes place at least twice a year.

14 through 17 Special Management: there is a strongly heightened credit risk. At least three times

a year, a report on these debtors is submitted to the Executive Board.

18 through 19 Special Management: there is a strongly heightened credit risk and/or the debtor

repeatedly fails to fulfil the payment obligations and/or there is no expectation of

continuity. At least three times a year, a report on these debtors is submitted to the

Executive Board.

31/12/2017 31/12/2016

EXPOSURE TO LOANS EXPOSURE TO LOANS AND ADVANCES AND AND ADVANCES AND OFF-BALANCE, OFF-BALANCE, EXCLUDING INCURRED % OF EXCLUDING INCURRED % OF LOSS PROVISION TOTAL LOSS PROVISION TOTAL

SOLVENCY-FREE LOANS AND ADVANCES 86,699 88% 89,513 89%

LOANS AND ADVANCES SUBJECT TO SOLVENCY REQUIREMENTSINTERNAL RATING:

– 1 through 11 10,567 11% 10,739 11%

– 12 through 13 363 0% 415 0%

– 14 through 17 507 1% 361 0%

– 18 through 19 38 0% 33 0%

11,475 12% 11,548 11%

TOTAL 98,174 100% 101,061 100%

20

EXTERNAL RATINGBNG Bank uses the external ratings awarded by rating agencies, specifically S&P, Moody’s, Fitch and DBRS. In determining the capital requirement, the bank uses the ratings of these four agencies if such ratings are available. Where possible, this applies to exposures to financial counterparties and investments in listed securities. The ratings relate to the counterparties themselves or specifically to the securities purchased.

FINANCIAL COUNTERPARTIESThe bank only conducts business with financial counterparties that have been rated by an external agency. Financial counterparties are periodically assessed for creditworthiness. This analysis includes an assessment of the internal rating. A limit is subsequently set or adjusted accordingly. The market risks associated with these parties are mitigated primarily through derivative transactions.

In order to reduce credit risk, netting agreements are agreed upon with financial counterparties with which BNG Bank actively concludes derivatives transactions. In addition, collateral agreements are concluded. These ensure that market value developments are mitigated on a daily basis by collateral. The agreements are updated where necessary in response to changing market circumstances, market practices and regulatory changes

COUNTERPARTIES WITH INVESTMENTS IN INTEREST-BEARING SECURITIES (IBS)BNG Bank’s IBS portfolio is held primarily for liquidity management purposes. The portfolio is composed of high-quality bonds, the majority of which are accepted as collateral by the central bank. BNG Bank’s total IBS portfolio can be subdivided into a liquidity portfolio and an ALM (Asset & Liability Management) portfolio. The liquidity portfolio consists exclusively of highly negotiable securities and is subdivided according to the various Liquidity Coverage Ratio (LCR) levels. The ALM portfolio is subdivided according to type of security. Each month, the development of the portfolio is reported to and discussed by the Investment Committee. Using factors such as external ratings and – in part – internal ratings, the bank monitors the development on an individual basis. The securities qualifying in accordance with the Delegated Act are subjected to a due diligence review process. The assets within these portfolios undergo an impairment analysis twice a year.

CONCENTRATION RISKRegarding of concentration risk, the bank differentiates between:– country risk with a distinction between domestic and foreign risk;– sector risk;– risk for individual parties with a distinction between clients and financial counterparties. Concentration risk is monitored by the first line as well as independently by the second line Risk Management department. Reports are submitted to the various committees and to the Management Board as the overarching authority. All policy decisions are taken by the Management Board, usually based on a recommendation by one of the sub-committees.

Alongside the risk concentration for solvency-free lending to the Dutch and other European governments, risk concentrations also exist in the market segments with exposures subject to solvency requirements, e.g. university hospitals. Almost all exposures to public sector entities subject to solvency requirements are secured by means of collateral or other securities. The other exposures subject to solvency requirements relate to financial institutions. Regarding



21

concentration risk, three (2016: five) of these financial institutions together represent an exposure of more than 10% of the Tier 1 capital.

DOMESTIC COUNTRY RISKA considerable degree of concentration risk to the Netherlands is inherent to BNG Bank’s mission: financing the Dutch public sector. A considerable portion of the exposure is indirectly related to public sector property. However, these risks are generally mitigated by government guarantees on lending and by the WSW and WfZ guarantee funds. These guarantees result in a concentration risk in relation to public authorities and guarantee funds. The guarantee funds are guaranteed by the government via backstop constructions. What results on balance is therefore a risk in relation to the Dutch State. The concentration of this risk is high, but inextricably linked to BNG Bank’s business model and to its place in the Dutch social system.

FOREIGN COUNTRY RISKThe bank is exposed to foreign country risk as a result of transactions with financial counterparties to hedge the market risks arising from lending activities, as a result of its liquidity portfolio and, to a limited extent, in the context of lending and investments in the public sector abroad. The bank consciously purchases foreign securities for its liquidity portfolio because the majority of its loan portfolio relates to the Netherlands. Foreign lending is in most cases directly or indirectly guaranteed by the relevant governments.

All foreign exposures fall within limits set for each country. These limits mainly depend on the credit quality of the country in question. Moreover, a general limit of 15% of the balance sheet total applies to the total of all foreign exposures.

After the creditworthiness of certain countries in the Eurozone deteriorated, the bank has gradually reduced its positions in these countries. This was mainly realised by expiration of exposures without replacing them with new exposures. At the end of 2017, the bank’s foreign exposure (expressed in balance sheet value) totalled EUR 24.1 billion (2016: EUR 23.8 billion), of which EUR 11.6 billion consisted of long-term exposures (2016: EUR 13.1 billion). This represents 8.3% of the balance sheet total (2016: 8.5%).

SECTOR RISKSector-specific policies and annual internal targets are used for lending without direct or indirect guarantees from the Dutch State. These sector targets relate to both maximum concentrations on the balance sheet and commercial targets for new transactions according to the bank’s Annual Plan. Active portfolio management is positioned within the Public Finance department. Realisation of the risk targets as well as the commercial targets is reported to the Management Board on a quarterly basis by the Risk Management department. The concentration risk per sector is also part of the Risk Management economic capital model used to assess the capital adequacy allocation.

INDIVIDUAL STATUTORY MARKET PARTIESIn terms of exposures to individual parties without direct or indirect guarantees from the Dutch State, maximum amounts apply to all parties that, regardless of individual credit quality, are much lower than the amounts permitted under the Large Exposure Regulation. These limits take into account the degree to which sectors are anchored in the public sector. Further limits are also established based on the party’s individual internal rating.



22

INDIVIDUAL FINANCIAL COUNTERPARTIESTransactions with these parties primarily consist of interest rate and currency swaps that are undertaken to mitigate market risks. Money market exposures can also apply. BNG Bank sets requirements for the minimum ratings of the financial counterparties with which it is willing to transact. This limits the number of available parties. As a consequence, the number of transactions with approved parties is high. Daily exchange of collateral helps to mitigate the credit risk from these parties with respect to derivatives in terms of market value, resulting in some operational risks. Default can also lead to market risks. Although the derivatives are measured at market value and the value of the collateral in this type of situation will be equal or close to the market value, the market is subject to fluctuations while the derivatives need to be rearranged with another party. The Financial Counterparties Committee limits and monitors positions with financial counterparties. Since 2016 the bank is clearing parts of its derivatives centrally. The bank uses five clearing members for this purpose. Central clearing has resulted in a shift in concentration risk from individual financial counterparties to the clearing members.

SETTLEMENT RISKExposure to settlement risks is limited to transactions with financial counterparties. Settlement risk is potentially high for those parties because of the relatively large size of the bank’s benchmark issues in foreign currencies. Netting and collateral agreements concluded with those parties serve to limit settlement risks resulting from the mutual offsetting of payments. Control measures throughout the operational process serve to further mitigate the settlement risk. The Bank Recovery and Resolution Directive (BRRD) that was introduced in Dutch law in November 2015, has included protection for settlement and payment systems in case of resolution of a bank, effectively reducing the settlement risk in parts of the financial system. An extensive review of the internal control measures was launched in 2016. Several follow up actions to improve practical mitigation have been implemented in 2017 and evaluation of further possible actions will continue in 2018. Capital allocation for settlement risk is based on an assessment of the likelihood of a possible loss from settlement risk and is updated yearly as part of the Internal Capital Adequacy Assessment Process.



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Market risk

DEFINITIONSMarket risk is defined as existing or future threats to the institution’s capital and results as a result of market price fluctuations. There are several forms of market risk: interest rate risk, foreign exchange risk, volatility risk and spread risk.– Interest rate risk: The current or prospective risk to earnings and capital arising from adverse

movements in interest rates. – Foreign exchange: The risk to annual results and capital arising from unfavourable exchange

rate fluctuations.– Volatility risk: The risk to annual results and capital arising from adverse movements in the

implied volatility of market interest rates or currencies. This risk only applies to products with types of optionality, such as caps and floors.

– Spread risk: The risk to annual results and capital arising from unfavourable credit risk spread fluctuations and unfavourable liquidity risk spread fluctuations.

GOVERNANCEThe Treasury and Capital Markets directorate is the ‘first line of defence’ and responsible for day-to-day market risk management. This directorate is responsible for hedging the market risks resulting from commercial activities. Additionally, the Treasury department has a mandate to adopt an interest rate risk position within the limits imposed by the Asset & Liability Committee (ALCO). The mandate for the ALCO to set limits is restricted by the capital that is explicitly allocated for this purpose. Stress scenarios are used to assess continuously whether this capital is sufficient.

The Risk Management Department is the ‘second line of defence’ and responsible for the independent monitoring of market risk and checks daily whether the risk positions are within their limits. The department prepares reports for the ALCO and the Treasury department and provides risks analyses and advice, both proactively and on request. By participating in the product approval process it also plays an important role in decisions to assume new market risks caused by new activities.

The ALCO is responsible for implementing the market risk policy. The ALCO consists of the Executive Board members, the Managing Director of Treasury and Capital Markets, the Head of Risk Management, the Company Secretary and the Senior economist, supplemented with other participators depending on the agenda.

MARKET RISKRISK MANAGEMENT OBJECTIVES


24

DEVELOPMENTSThe bank opted for a restrictive interest rate risk position in 2017. Because of an expected rise in interest rates, the interest rate position, measured in basis point sensitivity, was lower throughout the year compared to the long-term benchmark applied by the bank. The actual interest rate risk position took into account that the likelihood of an additional return in terms of market value due to a stable trend or further decline in interest rates did not sufficiently compensate for the possibly much larger loss of market value if interest rates would rise.

The benchmark reflects a continuously neutral investment of equity position in 10 years Dutch Government Bonds, which is in line with the required return of the shareholders. Compared to this the bank’s interest rate risk position in terms of mark to market outperformed the benchmark because the interest rates rose as expected.

Regarding its interest rate risk framework, the bank improved the measurement and monitoring of the credit spread risk. Furthermore, an interest rate gap analysis was designed and implemented in 2017, to complement the existing interest rate risk measures. Finally, a reverse stress scenario was added to the current parallel and non-parallel stress scenarios to determine under which circumstances the market risk limits set by the ALCO would be breached. In February the bank participated in the Interest Rate Risk in the Banking Book sensitivity exercise that was conducted by the ECB. The conclusion was that the bank was well capitalised to survive this stress scenario.

–0.2

–0.4

0

0.2

0.4

0.6

0.8

1.0

1.2

(in %

)

EUR Swap 2 years DifferenceEUR Swap 10 years

Janu

ary

2017

Febr

uary

017

Mar

ch 2

017

Apr

il 20

17

May

20

17

June

20

17

July

20

17

Aug

ust 2

017

Sept

embe

r 20

17

Oct

ober

20

17

Nov

embe

r 20

17

Dec

embe

r 20

17

EUROPEAN SWAP CURVE



25

INTEREST RATE RISKThe bank’s interest rate risk position is determined based on interest rates excluding credit and liquidity risk spreads and discounts. This means that changes in these spreads and discounts are not taken into account. The interest rate position in the banking book is internally managed in books for the Treasury department and the ALCO. The interest rate risk within the margin books (containing the lending and funding activities) and ALCO book (containing the active position) are transferred to the Treasury book by using internal swaps. The net interest rate risk in the Treasury book is externally hedged. Working on the basis of market forecasts from the departments Treasury and Economic Research, the ALCO periodically determines the bank’s interest rate outlook and defines – within the predetermined frameworks – the interest rate position and the limits and early warnings (target) levels within which the Treasury and Capital Markets directorate must operate.

The bank manages its interest rate position by using principal risk measures, which are monitored by the Risk Management department. The principal risk measure to monitor and manage interest rate risk applied by BNG Bank is the sensitivity (delta) of the economic value of the bank’s equity to changes in the interest-rate curve. The delta is determined for several maturity intervals on the interest rate curve and is reported daily. The ALCO manages the interest rate risk position based on the delta for each maturity interval.

In addition, the bank carries out daily and monthly scenario analyses on the economic value of the bank’s equity. These parallel and non-parallel stress scenario analyses are performed to cover both external requirements as well internal required levels.

Furthermore, BNG Bank analyses the basis risk between tenors and now uses an interest rate gap report. Next to that, the impact of interest rate stress scenarios on the interest results (Earnings at Risk) of the bank is monitored. All these interest rate risk measures complement each other and ensure the transparency and manageability of risks.

Any breach of a limit must be reported to the ALCO. The ALCO decides whether action should be taken immediately to adjust the interest rate position to a position within the limit or to authorize the limit breach for a certain period of time. Limits are set for the delta of the economic value per maturity interval and the scenario analysis outcomes. Early warning levels are set for the internal Earnings at Risk scenarios; the (tenor) basis risks and the interest rate gap analysis for which no direct action from the ALCO is required. The bank also sees to it that the outlier criterion is not exceeded, by applying an internal threshold value which serves as an early warning. The outlier criterion is prescribed by the Basel regulations, where it is used to express the maximum relationship between market risk and equity. In this context, the interest rate risk is measured under extreme conditions with an instantaneous parallel interest rate shock of plus or minus 200 basis points. The limits with respect to interest rate risk were not breached in 2017.

BNG Bank measures the sensitivity of its interest rate result using the Earning at Risk (EAR) measure. The EAR is for BNG Bank an appropriate measure because it monitors the effect of an interest rate shock scenario on an accrual basis. The table below outlines the effect of a minus 180 basis points gradual parallel interest rate shock for the 1 year and 2 year horizon at the end of 2017.



26MARKET RISKRISK MANAGEMENT OBJECTIVES


As the fair value items through profit & loss and for available for sale items are fully economically hedged for interest rate risk there is no sensitivity of these items on the economic value of equity.There is no material presence of early redemption options in BNG Bank’s regular loan portfolio. Likewise, there is no material exposure in mortgages and the bank does not attract savings from private individuals. Consequently there is no necessity to model client behaviour in its interest rate risk models.

FOREIGN EXCHANGE RISKThe bank obtains a large portion of its funding in foreign currencies and is thus exposed to major potential foreign exchange fluctuations. The bank’s policy specifies that all foreign exchange risks should be hedged in full and executes this policy. Incidentally, foreign exchange positions may occur in certain cases where it is not cost-efficient to hedge the risk. The foreign exchange risk of these minor positions is monitored on a daily basis, subject to limits. During 2017 these limits were not breached.

VOLATILITY RISKIn managing its interest rate exposure, the bank has allowed a very limited range for assuming volatility risk to support the active interest rate position. This range is limited and monitored by the Risk Management department on a daily basis. During 2017 the Treasury department did not assume any additional volatility risk to support the active interest rate position.

With regard to its other activities, BNG Bank’s policy specifies that the volatility risks for new products should be hedged in full. There is still some minor exposure to volatility risks with a legacy character.

SPREAD RISKThe economic value of BNG Bank’s equity is determined over its total portfolio of assets and liabilities. Both assets and liabilities are valued on the basis of an interest rate curve made up of market-based swap rates plus credit and liquidity risk spreads. In case of cross currency swaps the cross currency basis spread is included in the market value. The impact of changes in these spreads and is monitored on a daily basis. For a small part of the fair value instruments accounted through profit and loss the ALCO has set a warning level on the spread delta

HEDGING OF RISKS WITH DERIVATIVESAs described above, BNG Bank applies economic hedging in order to mitigate foreign exchange risks and keep interest rate risks at a desired level. To this end, the bank has put in place a system of limits and procedures that is strictly adhered to and is monitored on a daily basis. Foreign exchange and interest rate risks are hedged with derivatives. The treatment of derivatives and

2017 2016

EARNINGS AT RISK

(in EUR million)

Horizon

1Y –16 –13

2Y –86 –54

27

hedged items in the balance sheet and income statement is such that they are aligned as much as possible with the actual economic hedging. For accounting purposes, BNG Bank processes this hedging relationship under IFRS by applying micro and portfolio fair value hedging, as well as cash flow hedging.

Micro fair value hedging (MH) is applied to individual transactions involved in an economic hedge relationship to offset interest rate risks. This form of hedging is applied to nearly all debt securities issued. The foreign exchange and interest rate risks are hedged by means of derivatives, mainly (cross-currency) interest rate swaps. The issues are fully offset against the derivatives so that, on a net basis, the fixed coupons of the issues are converted into variable interest amounts in euros. Both the issues and the accompanying derivatives can contain structures, such as options, which are also fully offset. The revaluation effect of hedged MH transactions with regard to fair value hedging is accounted for in the same balance sheet item as the hedged items.

BNG Bank applies (micro) cash flow hedge accounting to virtually all long-term funding transactions in foreign currencies in order to protect the bank’s result against possible variability in future cash flows due to exchange rate fluctuations. The basis swap spread is an important building block of the value of a cross-currency (interest rate) swap. Therefore, if seen as a separate financial instrument, the fair value of these swaps is influenced by the change in the basis swap spread. However, this change has no economic effect on the bank and it, in principle, never will, as the bank will generally retain the contracts until their maturity. With the exception of voluntary early redemption of funding in foreign currencies or an immediate and complete withdrawal from the banking business, there are no circumstances under which these negative revaluations can lead to a realised result.

In portfolio fair value hedging (PH), the interest rate risks of a group of transactions are hedged by means of a group of derivatives. The hedging relationship is constructed and controlled at an aggregate level, thus precluding relationships with individual transactions. Within BNG Bank, portfolio hedging, like micro hedging, has been highly effective in recent years. Any ineffectiveness that occurs is recognised in the income statement.

Although BNG Bank uses derivatives for economic hedging purposes, it is not possible in all cases to include these in a hedge accounting relationship, as permitted by IFRS. For the derivatives that are not involved in a hedge accounting relationship, in virtually all cases there is an economic hedged position which is also recognised at fair value through the income statement so that, in total, the volatility of the result due to interest rate and foreign exchange risks is limited.



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Liquidity risk and funding risk

DEFINITIONSLiquidity risk is defined as the existing or future threat to the institution’s capital and results due to the possibility that at any moment it will not be able to fulfil its payment obligations without incurring any unacceptable costs or losses.− Short-term liquidity risk: The risk that the bank will not be able to attract sufficient funds to

meet its payment obligations.− Refinancing or long-term liquidity: The risk that the bank will not, as a result of its own

creditworthiness, be able to attract any (or sufficient) funds against prices that won’t jeopardise its continuity.

GOVERNANCEThe Treasury and Capital Markets directorate is the ‘first line of defence’ and responsible for the day-to-day liquidity and funding risk management. They are responsible to attract funding resulting from commercial activities. The Treasury department is mandated to adopt a liquidity risk position within the limits and triggers imposed by the ALCO. Stress scenarios are used to continually assess the liquidity risks, in order to determine whether the liquidity and funding is sufficient.

The Risk Management department is the ‘second line of defence’ and responsible for the independent monitoring of liquidity risk and daily checks whether the bank remains within its limits and triggers set by the ALCO. The Risk Management department independently reports to the ALCO and to the Treasury department on the use of predetermined limits and provides risks analyses and advice, both proactively and on request. Liquidity and funding risk measures such as liquidity gap analysis, contingency funding plan, and stress scenarios regarding the survival period are monitored against limits or triggers, both short term and long term. The Risk management department is also instrumental in the decision to accept liquidity and funding risks as part of the product approval process.

If liquidity limits or triggers are breached, the Contingency Funding Plan is enforced. Additional ALCO meetings, temporary procedures for more intensive liquidity management and temporary control of liquidity management by the liquidity contingency team are the main elements of this plan.

LIQUIDITY RISK AND FUNDING RISKRISK MANAGEMENT OBJECTIVES


29

DEVELOPMENTSIn the last quarter of 2017, BNG Bank decided to continue long term prefunding, by exceeding the funding target for 2017 of EUR 15.6 billion by EUR 1.3 billion. The main reasons are funding of collateral and attractive pricing of liquidity. Regarding alternative funding, negotiations on a new Global Loan Facility were finalised in during the last quarter. This Global Loan of EUR 300 million is provided by Council of Europe.

In 2017 BNG Bank has improved the Internal Liquidity Adequacy Assessment Process stress scenarios by adding more scenarios including a reverse stress scenario, remodelling collateral outflows and fine-tuning other input parameters to get a better insight in the bank’s liquidity position.

In addition, ALCO reporting was improved by implementing a monthly liquidity risk dashboard. Furthermore, the bank improved the measurement, reporting and monitoring of the funding spread risk. Funding spread risk is the accrual margin change due to increased funding spreads which cannot be passed through to the spreads of new assets. This risk is caused by the liquidity mismatch between assets and liabilities. The ALCO has set an early warning level for the 1 year horizon funding spread risk.

Finally, the bank is working on a forward-looking model to monitor the Net Stable Funding Ratio (NSFR) more closely.

LIQUIDITYBNG Bank wants to provide a constant and stable presence in the market and want to continue to meet the demand for credit, even in difficult times. It also pursues a prudent liquidity position to ensure that it can meet its obligations at all times. In this context, ongoing access to the money and capital markets is essential, and with it, the ongoing maintenance of attractive, varied and sufficiently large issue programmes for investors. In addition, buffers are required in order to have access to liquidity in times of stress. One such buffer is formed by assets held explicitly for liquidity purposes, known as the liquidity portfolio. The management of the size and composition of this portfolio is one of the liquidity measures to comply with the requirement under the CRR to have an LCR of at least 100%. BNG Bank also holds an ample quantity of collateral with the central bank, which enables it to obtain short-term funding immediately. Since most of the banks assets could serve as collateral, this collateral may be further extended in the event of prolonged stress.

The limits on funding deficits in the short term and in the long term are an explicit part of the risk appetite and directly determine the level of the principal liquidity limits. BNG Bank also calculates survival periods. The survival period is the period in which the standard liquidity buffers are sufficient for absorbing the consequences of a stress scenario. Survival periods are determined under a range of stress scenarios. During 2017, the survival periods indicated by the stress tests met the requirement laid down in the risk appetite to be able to endure nine months without access to capital market funding. During this period, the bank is also capable to provide its core client groups with liquidity, fulfilling its ambition to assist its clients even in difficult times.

The bank believes that during 2017 its liquidity management was adequate and that the strength of the bank’s liquidity position is both amply sufficient and in compliance with the regulatory standards and limits set by the ALCO.



30

LCR DISCLOSURE TEMPLATE (EU LIQ1)



SCOPE OF CONSOLIDATION (CONSOLIDATED) TOTAL UNWEIGHTED VALUE TOTAL WEIGHTED VALUE

CURRENCY AND UNITS (EUR MILLION) 31/12/ 30/09/ 30/06/ 31/03/ 31/12/ 30/09/ 30/06/ 31/03/ 2017 2017 2017 2017 2017 2017 2017 2017

NUMBER OF DATA POINTS USED IN THE CALCULATION OF AVERAGES 12 12 12 9 12 12 12 9

HIGH-QUALITY LIQUID ASSETS

1 Total high-quality liquid assets (HQLA) – – – – 25,006 23,792 21,204 19,201

CASH-OUTFLOWS

2 Retail deposits and deposits from small

business customers, of which: 0 0 0 0 0 0 0 0

3 Stable deposits 0 0 0 0 0 0 0 0

4 Less stable deposits 0 0 0 0 0 0 0 0

5 Unsecured wholesale funding 15,513 13,672 12,440 11,083 12,468 11,953 11,213 10,011

6 Operational deposits (all counterparties)

and deposits in networks of

cooperative banks 0 0 0 0 0 0 0 0

7 Non-operational deposits

(all counterparties) 5,506 5,028 4,876 4,569 3,824 3,308 3,649 3,496

8 Unsecured debt 10,008 8,645 7,564 6,515 8,645 8,645 7,564 6,515

9 Secured wholesale funding – – – – 7 0 0 0

10 Additional requirements 16,995 16,941 16,844 16,769 6,634 6,630 6,620 6,612

11 Outflows related to derivative exposures

and other collateral requirements 5,350 5,357 5,357 5,357 5,350 5,357 5,357 5,357

12 Outflows related to loss of funding on

debt products 0 0 0 0 0 0 0 0

13 Credit and liquidity facilities 11,645 11,584 11,488 11,412 1,284 1,273 1,263 1,255

14 Other contractual funding obligations 5 5 5 5 0 0 0 0

15 Other contingent funding obligations 88 91 102 105 5 16 16 20

16 TOTAL CASH OUTFLOWS 32,601 30,709 29,391 27,961 19,107 18,598 17,849 16,642

Continued on next page

31LIQUIDITY RISK AND FUNDING RISKRISK MANAGEMENT OBJECTIVES


Continuation of previous page

SCOPE OF CONSOLIDATION (CONSOLIDATED) TOTAL UNWEIGHTED VALUE TOTAL WEIGHTED VALUE

CURRENCY AND UNITS (EUR MILLION) 31/12/ 30/09/ 30/06/ 31/03/ 31/12/ 30/09/ 30/06/ 31/03/ 2017 2017 2017 2017 2017 2017 2017 2017

NUMBER OF DATA POINTS USED IN THE CALCULATION OF AVERAGES 12 12 12 9 12 12 12 9

CASH-INFLOWS

17 Secured lending (eg reverse repos) 21 21 0 0 2 2 0 0

18 Inflows from fully performing exposures 5,115 4,951 4,560 4,603 3,541 3,253 3,253 3,001

19 Other cash inflows 0 0 0 0 0 0 0 0

EU-19A (Difference between total weighted

inflows and total weighted outflows

arising from transactions in third

countries where there are transfer

restrictions or which are denominated

in non-convertible currencies) – – – – 0 0 0 0

EU-19B Excess inflows from a related specialised

credit institution) – – – – 0 0 0 0

20 TOTAL CASH INFLOWS 5,136 4,972 4,560 4,603 3,544 3,255 3,253 3,001

EU-20A Fully exempt inflows 0 0 0 0 0 0 0 0

EU-20B Inflows Subject to 90% Cap 0 0 0 0 0 0 0 0

EU-20C Inflows Subject to 75% Cap 4,019 4,787 6,299 3,543 1,765 3,403 4,388 3,001

21 LIQUIDITY BUFFER – – – – 25,006 23,792 21,204 19,201

22 TOTAL NET CASH OUTFLOWS – – – – 15,563 15,343 14,596 13,642

23 LIQUIDITY COVERAGE RATIO (%) – – – – 161% 155% 145% 141%

FUNDINGBNG Bank distinguishes between short-term and long-term funding. The majority of funding is from institutional capital markets. The bank maintains a number of programmes that enables it to have access to liquidity at all times at competitive levels. The bank pursues pro-active investor relations which supports these efforts.

The following resources are used for short-term funding:− Commercial Paper: the bank has a European Commercial Paper (ECP) programme of EUR 20

billion and a US Commercial Paper (USCP) programme of USD 15 billion. Under normal circumstances, a substantial margin is maintained between the maximum size allowed under the programme and the bank’s actual usage;

− Repurchase transactions with interbank parties under a Global Master Repurchase Agreement (GMRA) where the bank’s liquidity portfolio is used to pledge as collateral;

− Deposits from institutional money market parties.The bank does not enter into transactions with private individuals and therefore has practically no retail deposits.

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The following programmes are available for long-term funding:− the Debt Issuance Programme (DIP) of EUR 100 billion. Socially Responsible Investing (SRI)

bonds are also issued under this programme;− the Kangaroo-Kauri Programme, specifically for the Australian and New Zealand market, of

AUD 10 billion;− the Samurai shelf registration and Uridashi shelf registration, specifically for Japanese investors;− the Namen-Schuld-Verschreibungen (NSV), under German Law;− and Private loan agreements.

For reasons of diversification, the bank also uses the following alternative funding sources in order to finance its activities:− Global loans from the European Investment Bank and the Council of Europe development

Bank;− Guaranteed Investment Contracts (GICs).

The bank has a funding plan in which the desired funding mix is described in more detail. Part of the funding plan is the annual issuance in benchmark size. These large-scale issues ensure that the bank has a high profile among investors, allowing it to retain access to investors even in times of market stress. The actual realisation of this desired funding mix or the reason for diverging from it is monitored and reported to the ALCO.



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Operational risk

DEFINITIONSOperational risk is defined as the risk of losses due to the shortcomings of internal processes, people and systems, or as a result of external events. In addition to the general operational risk, operational risk comprises the following risks:– IT risk is the risk that business processes and information systems are supported by information

technology whereby protection is insufficiently sound, discontinuous or unsatisfactory.– Outsourcing risk is the risk that the continuity, integrity and/or quality of activities

outsourced to third parties or the equipment or staff provided by these third parties is adversely affected.

– Integrity risk is the risk that the institution’s integrity is adversely affected by unprofessional or unethical behaviour by the organisation or its employees and clients in breach of applicable legislation and regulations, or social and institutional standards.

– Legal risk is the risk associated with (changes in and compliance with) legislation and potential threats to the institution’s legal status, including the possibility that contractual stipulations prove unenforceable or have been incorrectly documented.

GOVERNANCELine management has primary responsibility as the ‘first line of defence’ for managing operational risk in day-to-day operations, in conformity with policies and arrangements. In this, it is supported by specialised departments, such as the Internal Control department. Although operational risks cannot be fully mitigated, they must obviously be made transparent and manageable.

The departments Risk Management, Compliance and Security constitute the ‘second line of defence’ and are responsible for providing an overview and understanding of risks, as well as control guidelines. They support and advise line management by facilitating periodical risk control self assessments and by analysing operational risks. The risks, control measures and residual risks are identified and documented. The second line will propose supplementary control measures where necessary and monitor their timely implementation. Residual risks will be communicated to the responsible manager, who will, if applicable, advise the Executive Board on their acceptance. The Risk Management department is involved in projects and process changes in the context of operational risk management. The compliance officer is responsible for the periodical integrity risk analyses.

The IAD conducts independent assessments in supplement to the risk analyses by the departments Risk Management, Compliance and Security and the activities of the Internal Control department, in order to determine the existence and effect of control measures. The IAD thereby constitutes the ‘third line of defence’ and reports to the Executive Board.

OPERATIONAL RISKRISK MANAGEMENT OBJECTIVES


34

Each year, the managing directors and the other direct reports inform the Executive Board whether they are in control of the processes and risks for which they are responsible.

DEVELOPMENTSThe focus on data quality has led to the introduction of the Data and Information Management department in 2016. This department is, amongst others, responsible for developing a joint data warehouse and has a leading role in the implementation of data governance processes. Business departments have a major responsibility for data quality. The aim of the data warehouse is to meet internal information needs, but also to comply with rapidly evolving external requirements like the Principles for Effective Risk Data Aggregation and Reporting (PERDARR). Often strict deadlines apply to requests for information both in normal and in times of stress or crisis. The bank must be able to produce risk information quickly and correctly.

The pilot within the credit process with a new style of working based on the Lean philosophy has resulted in working in multidisciplinary teams. Effectiveness and efficiency have improved, while preserving the controlled operations. Implications for employees have the attention of the management.

Several projects to ensure compliance to laws and regulations have started and have a considerable impact on business processes (notably MiFID/MiFIR and the General Data Protection Regulation).

The insight provided in operational risk has improved. In the quarterly Risk Report to the Executive Board and the Supervisory Board the operational risk exposure is measured and reported by the Risk Management department. For operational risk the use of an extensive set of indicators is relatively new and further tuning will be applied in 2018. The Risk Management department gives an opinion on the most important non-financial risks and has asked explicit management attention for the many simultaneous changes the bank is facing. The number of operational incidents did not materially increase in 2017.

Operational risk has a soft component, also referred to as ‘culture’. BNG Bank is convinced of the importance of this component. To improve the risk awareness various operational risk management activities are performed, such as periodically performing risk self assessments for all processes and taking the so called banker’s oath by all employees.

In 2017, the Information Security Officer was positioned in the Processing department instead of the Compliance department. This led to the enhancement of the information security function within the Processing directorate. In 2018 the bank will decide on a definitive positioning of the Information Security Officer.

GENERALBNG Bank registers all operational incidents with a potential impact of EUR 5,000. To this end, employees involved in the operational process are obliged to report all operational incidents to the Risk Management department. Remedial actions directly related to the incident are the responsibility of the first line. Additionally, the Risk Management department conducts an assessment in order to determine whether the prevention of future similar incidents will require any adjustments to the process, systems or working methods. Every quarter, the Risk Management department reports to the Executive Board and senior management on incidents with a possible



35

impact from EUR 10,000 upwards. It also provides annual reports on incidents involving a loss of more than EUR 100,000 to the Executive Board and the Supervisory Board’s Audit & Risk Committee. For 2017 the Incidents Report contains two incidents with an impact in excess of EUR 100,000. The impact of operational incidents on the bank’s annual results in 2017 was limited. Incidents which pose a serious threat to the ethical conduct of the business must be reported to the regulator. No such incidents occurred in 2017.

IT RISKThe bank’s information policy aims to develop and maintain information systems that allow the bank to continue executing its company strategy successfully. The information policy is reviewed annually, based on the business strategy objectives and external developments.

The management of IT risk is based on the application of preventative rather than remedial measures. These measures are aimed at preventing (potential) incidents or detecting them at the earliest possible opportunity and preventing the potential damages or restoring the desired situation as quickly as possible. In order to guarantee the continuity of IT support at the bank, a yearly fall-back test is conducted. Also in 2017 the test demonstrated that the bank’s backup systems are adequately equipped to ensure that services continue as normal in the event of a calamity. Furthermore, the systems are frequently tested for vulnerabilities to hacking. All bank employees received information security training in 2017 in the form of interactive information sessions and e-learning. There were no major information security incidents in 2017.

To limit the IT risk, the bank seeks to reduce the complexity of its IT systems. The dynamics of the financial markets and statutory and regulatory requirements continue to constitute a challenge to the bank in this regard, resulting in a substantial project portfolio. The development of a central data warehouse also requires a large amount of IT capacity and will continue to do so in the next few years. Where necessary, external expertise and capacity is used. So far results are encouraging.

Agile working has been adopted for carrying out projects. A team which consists of employees of the business side, analysts and developers are working together in close collaboration to achieve the desired result. The ‘product owner’ has the deciding vote within the team, taking into account the interests of all stakeholders. Per project the most suitable project approach is selected. All projects are initiated and managed via the project portfolio. Many system adjustments are still prompted by changing laws and regulations.

OUTSOURCING RISKBNG Bank’s most important outsourcing contract relates to the outsourcing of the payment transaction process and a large portion of the bank’s IT activities to Centric FSS. These activities include payment services and current account administration, the computing centre and workstation management. BNG Bank’s activities are linked to those carried out by Centric FSS via Service Level Agreements (SLAs) and the bank’s internal demand organisation. BNG Bank regularly monitors and evaluates the service provider’s services. The ISAE 3402 statement annually issued by Centric FSS is part of this procedure. The IAD’s periodical audits of Centric FSS provide extra assurance. The bank also structurally monitors the financial situation of Centric FSS and draws up contingency plans. Other services, such as the management of the building and installations, catering, cleaning and landscaping, have also been outsourced, with satisfactory results.



36

Cloud computing is becoming more and more common practice. BNG Bank is treating cloud computing as a way of outsourcing and performs a risk analysis as part of the outsourcing decision. Classification and ultimate destination of the data and the characteristics of the outsourcing party and the application are important factors in the decision. The decision to allow a cloud application is made by a multidisciplinary team.

INTEGRITY RISKIntegrity is a key part of the operations. The BNG Bank Code of Conduct (see website), featuring the core values: reliable, sustainable and professional, serves as a guideline for all actions undertaken by BNG Bank and its employees. New staff are assessed on their integrity before they take up their duties, irrespective of whether it concerns internal or external staff. The issue of integrity is highlighted among all staff on a regular basis. All current employees have individually taken the banker’s oath and endorse the disciplinary regulations for banks. New staff also individually take the banker’s oath and endorse the disciplinary regulations for banks. When employees take the oath, the importance of ethical conduct is discussed. The bank carries out a product approval process to ensure that its products serve the interests of its clients and do not involve any unacceptable risks for the clients and for the bank itself. The bank values acting with due care towards clients and other stakeholders over an exclusive focus on financial profit or other self-interests. The bank also expects its clients and other contacts to adhere to ethical standards and not to place the bank’s reputation at risk. The bank has drawn up policy rules for this purpose, that are used as a basis for assessing new and existing clients and contacts. Compliance with internal and external rules is regularly reviewed within the bank. The Compliance department periodically carries out an integrity risk analysis and has not detected any major integrity issues in 2017.

LEGAL RISKThe bank has a specialist legal department whose tasks and responsibilities include drafting legally sound arrangements with clients and other parties. To this end, standard contracts and provisions have been drawn up, which are managed in an internal (contract) models library. Any deviation from these standard contracts is coordinated with the Legal Affairs, Tax and Compliance department (JFC).

The bank has automated the administration of contractual provisions in agreements with clients, with the aim to standardise the conditions and provisions as much as possible. The internal (contract) models library is aligned with the contract administration and is subject to continuous further development and updating. This guarantees the enforceability of contractual agreements as much as possible, and the standardisation of conditions will result in an operational process that involves as little manual intervention as possible.

Where applicable, the JFC department seeks external assistance, for example in the event of complex (often syndicated) transactions and in cases requiring specialist legal knowledge.

As at year-end 2017, BNG Bank was not involved in any material legal proceedings.



https://www.bngbank.nl/bedrijfscode

37

Strategic risk

DEFINITIONSStrategic risk is defined as the risk that strategic decisions of the institution itself could result, in the execution of those decisions, in losses and/or the chance of losses as a result of changes beyond the control of the institution or group in the area of the bank’s competitive position, the political climate, regulatory developments, reputation and business climate. In addition to general strategic risks, the following aspects can be identified:– Reputation risk: The risk that the institution’s market position will deteriorate due to a

negative perception of its image amongst stakeholders.– Business climate: The likelihood of losses due to environmental changes in terms of the

economy, stock exchange climate, wage and/or purchasing power developments, broader society, technology and by the activities, actions and/or decisions of (new) competitors.

– Political risk: The risk that the institution’s competitive and market position will be influenced by the political climate and stakeholder influence.

– Regulatory risk: The risk that developments in regulatory requirements will materially impact the business model and complexity of operations.

GOVERNANCEStrategic risks are driven by external factors in particular and hence are less easily influenced or predictable. Furthermore, strategic risks are often closely interlinked with one of the other risk types (e.g. operational risks can have an effect on the reputation of BNG Bank or a changing business climate causes changes in the credit risk or interest rate risk profile of BNG Bank). Therefore, strategic risk has no dedicated general policy of its own. Instead, strategic risks are incorporated in the annual plan of BNG Bank and the business plans of the individual departments. Strategic risk is also addressed in the Capital Management Plan (as part of the ICAAP). Decisions on strategic risk are the responsibility of the Executive Board, although discussions generally also take place in Management Board or ALCO meetings depending on the exact nature of the strategic risk. The monitoring is organized by means of the planning- and budget cycle.

DEVELOPMENTSStrategic risks are driven by the external environment of the bank which is evolving continuously. As usual, the bank has been in close contact with its stakeholders to discuss and evaluate these developments. From a strategic perspective, the bank has focussed on three major subjects.

Firstly, from a perspective of competition, the bank has increased its efforts to operate close to its customers interests, by communicating with them in many ways but also in developing new products and updating existing products according to their wishes, whilst retaining its sharp

STRATEGIC RISKRISK MANAGEMENT OBJECTIVES


38

pricing profile. Competition from other banks as well as institutional investors was more fierce in 2017 than in the preceding years, although the bank was able to hold the balance between retaining acceptable margins and substantial market shares in new transactions. From its scale and business model, it is not necessary and, from a cost perspective, not desirable to be a technological frontrunner. However, smart following including continuous innovation is necessary for customer experience as well as cost efficiency.

Secondly, the bank has continued its efforts in the field of sustainability, which is described in more detail in the annual report. An example in this respect was the development of a Sustainability Fund for specific projects.

Thirdly, the bank is focusing on organisational flexibility in the field of human resource management. Job rotation as well as life long learning is actively promoted by the Management Board and is supported by a range of learning facilities, including coaching. The job market is already tight for staff with the required qualifications and expected to be tightening further. Especially staff with a combination of relevant technical skills and in depth knowledge of banking is scarce and job rotations as well as internships stimulate existing staff to extend its skills, thus reducing the risk of job loss caused by changing demands.

Furthermore, the bank has closely followed all developments regarding Brexit. In terms of assets, the exposure to the UK is relatively small and the quality of these assets is high. For funding purposes the bank is not materially dependent on the UK. Furthermore, the bank has virtually no exposure to the EUR/GBP exchange rate. The most extensive ties with the UK relate to the large amount of derivatives transactions with banks in the UK and to central clearing through the clearing house LCH. In general, larger banks in London are in talks with the European Central Bank about moving operations to the European mainland to prepare for the situation that Brexit takes place without a trade deal between the EU and the UK. Clearing houses of systemic importance like LCH may be explicitly forced by the EU to move to a location within the EU. The bank discusses the developments related to Brexit in its Financial Counterparty Committee.

In 2017 no specific further events or changes occurred that materially changed the strategic risk profile of BNG Bank. Neither did the processes to monitor and analyse these strategic risks.

REPUTATION RISKBNG Bank always aims to provide products and services that are in the client’s interest. This is of vital importance for its reputation as a bank of and for the public sector. This is reflected not only in the bank offering products that its clients ask for, but especially in a certain reticence if it is not sufficiently clear that a particular product is in the clients’ interest. The bank will stress this when it receives requests for financing arrangements which it considers unsuitable for the client concerned. This applies in particular to smaller organisations of which the bank has reason to believe that they lack the in-house expertise to manage the risks of the product in question. This is factored into the bank’s product approval process.

Naturally, reputation risk also applies to the bank’s other stakeholders, such as investors and shareholders. It often arises as a consequential risk if other risks are not properly controlled. Therefore, it makes up an integral part of all aspects of the bank’s risk policy. Mitigation of the various risks therefore indirectly safeguards the bank’s reputation.



39

To provide its clients with innovative forms of lending, a limited time to market is desirable from a strategic as well as a commercial perspective. However, insufficient care during implementation can lead to problems that could harm the bank’s reputation. In 2017 the existing product approval process has been supplemented with a formal Product Approval and Review Policy as well as extensive product approval templates. In these templates much attention is paid to the suitability of products for the banks clients. The new product approval templates will be filled for new as well as existing products. Part of this has taken place in 2017 and the other products will follow in 2018.

Since reputation risk is included in the risk appetite of the bank, it is also part of the associated monitoring.

BUSINESS CLIMATE The low interest rate environment in the EU has a lowering effect on earnings and return on equity. The relatively long maturities of the bank’s assets result in a slower materialisation of this effect for BNG bank than for most other banks. However, the effect is still there. Given the fact that the interest rate environment is explicitly taken into account in the shareholders opinion on the required return and that the shareholders are not demanding a maximum but only a reasonable return on their shareholdings the interest rate environment as such is not threatening the business model of the bank.

The relatively low credit margins characteristic of the market in which BNG Bank operates act as an obstacle to potential new entrants. Scale and efficiency are key to a profitable business model. Parties striving to maximise their profits will thus enter this market on a limited scale. Although competition is still relatively limited, as described above, it has increased due to the fact that institutional parties such as pension funds and insurers do enter this market on an irregular basis. Other parties are show an interest in financing DBFMO projects.

POLITICAL RISKAt BNG Bank, business climate and political risk are closely linked, because public authorities are both shareholders and clients. Therefore, BNG Bank has a high dependency risk with respect to political decisions. Especially decisions that impact regulations for client sectors that represent large portions of the bank’s balance sheet. Due to public sector cuts in recent years, BNG Bank’s loan portfolio marginally declined.

The political climate with respect to the different sectors in which BNG Bank operates has stabilised in 2017 compared to the preceeding years. For the longer term, BNG Bank expects that a smaller part of the funding of the housing sector will be guaranteed by the Social Housing guarantee fund than is now the case. This will impact the credit risk profile of these loans. Developments are being monitored continuously. If any changes would be decided upon, these are expected to be implemented incrementally, allowing for a smooth transition for the housing sector.

BNG Bank incidentally invested modest amounts of risk-bearing capital in area development projects. This allows the bank to participate in such projects also in its capacity as lender. Market conditions in this sector have been difficult after the crisis of 2008, and activities are directed primarily at managing and phasing out the existing portfolio. New projects are only considered if the risk profile is considerably safer than before.



40

REGULATORY RISK Changing regulations remain a potential threat. The bank is specifically exposed to potential changes in solvency requirements based on notional amounts, like the total size of the balance sheet, because almost all of its assets are low risk and most of them are even zero risk weighted. Another potential threat is the Bank Recovery and Resolution Directive (BRRD) by the EU, which poses the question of whether the shareholders are permitted to assist BNG Bank in the event of acute problems, without rising discussions on state aid or a bail-in. The details of the directive governing the MREL requirement (Minimum Requirement for own funds and Eligible Liabilities) can also affect how the bank meets its funding needs. The precise form of these bail-in regulations as well as the interpretation by the Single Resolution Board in the context of promotional banks is still undetermined.

In the long term further changes are to be expected as the Basel Committee published in December 2017 a report on further reforms of the regulatory framework. For full implementation of these reforms a transition period is included up to 2027. These reforms now need to be incorporated in the regulatory framework of the European Union in the upcoming years. Currently, potential impact on capital or liquidity requirements seems limited on BNG Bank. However, the incorporation of these reforms in EU regulation will determine the exact impact. And besides any direct capital or liquidity impact the associated reporting requirements and implementation of regulations might take up considerable resources of BNG Bank.



41

Scope of application (article 436 CRR)

The requirements of the Capital Requirements Regulation apply to the N.V. Bank Nederlandse Gemeenten (BNG Bank). BNG Bank has two subsidiaries that operate in support of the bank’s core business activity. There is no difference in scope of consolidation for accounting and prudential purposes for BNG Bank. Each year, BNG Bank prepares consolidated financial statements for the parent company and its subsidiaries. The financial statements of the parent company and its subsidiaries which are used to prepare the consolidated financial statements are drawn up at the same reporting date, and are based on uniform principles. All intra-group transactions and balances, including income, expenses and dividends, have been fully eliminated in the consolidated financial statements. The consolidated financial statements comprise the following subsidiaries over which BNG Bank has control:– BNG Gebiedsontwikkeling: To directly or indirectly provide (venture) capital to public

authorities and to directly or indirectly participate in and/or cooperate with projects, either with or on behalf of public authorities or institutions affiliated with public authorities.

– Hypotheekfonds voor Overheidspersoneel: The financing of mortgage loans taken out by civil servants in the employ of an affiliated public or semi-public institution with which a cooperation agreement has been reached.

SCOPE OF APPLICATION

(ARTICLE 436 CRR)

42

Differences between accounting and regulatory

scopes of consolidation and mapping of financial

categories to regulatory risk categories (EU LI1)

DIFFERENCES BETWEEN ACCOUNTING AND REGULATORY SCOPES

OF CONSOLIDATION AND MAPPING OF FINANCIAL CATEGORIES TO

REGULATORY RISK CATEGORIES (EU LI1)


(ARTICLE 436 CRR)

43

31/12/2017

ASSETS

Cash and balances with the

central banks 2,996 2,996 – – – –

Amounts due from banks 13,997 105 13,892 – 3 –

Financial assets at fair value

through the income statement 2,006 1,798 – 208 913 –

Derivatives 8,982 – 8,982 – 2,902 –

Financial assets available-for-sale 14,110 11,064 – 3,021 683 25

Loans and advances 86,008 85,956 – 52 131 –

Value adjustments on loans in

portfolio hedge accounting 11,813 11,813 – – – –

Investments in associates and

joint ventures 47 47 – – – –

Property & equipment 17 14 – – – 3

Other assets 19 19 – – 1 –

Assets Held-for-Sale 30 30 – – – –

TOTAL ASSETS 140,025 113,842 22,874 3,281 4,633 28

LIABILITIES

Amounts due to banks 2,393 – 314 – 1,832 247

Financial liabilities at fair value

through the income statement 944 – – – 810 134

Derivatives 21,870 – 21,870 – 3,495 –

Current Tax Liability 17 – – – – 17

Deferred Tax Liability 173 – – – – 173

Debt securities 104,127 – – – 54,424 49,703

Funds entrusted 5,472 – 55 – 1,947 3,470

Subordinated debts 31 – – – – 31

Other liabilities 45 – – – – 45

TOTAL LIABILITIES 135,072 – 22,239 – 62,508 53,820


(ARTICLE 436 CRR)

CARRYING VALUES AS

REPORTED IN PUBLISHED FINANCIAL

STATEMENTS AND FOR

REGULATORY CONSOLI-

DATION

CARRYING VALUES OF

ITEMS SUBJECT TO

CREDIT RISK FRAMEWORK

CARRYING VALUES OF

ITEMS SUBJECT TO

COUNTER-PARTY CREDIT

RISK FRAMEWORK

CARRYING VALUES OF

ITEMS SUBJECT TO

SECURITI-SATION

FRAMEWORK

CARRYING VALUES OF

ITEMS SUBJECT TO

MARKET RISK FRAMEWORK

CARRYING VALUES OF ITEMS NOT

SUBJECT TO CAPITAL RE-

QUIREMENTS OR SUBJECT TO

DEDUCTION OF CAPITAL




44

31/12/2016

ASSETS

Cash and balances with the

central banks 6,417 6,417 – – – –

Amounts due from banks 11,795 254 11,541 – 3 –

Financial assets at fair value

through the income statement 2,350 2,118 – 233 961 –

Derivatives 15,412 – 15,412 – 7,787 –

Financial assets available-for-sale 15,437 12,235 – 3,172 785 29

Loans and advances 87,576 87,522 – 54 139 –

Value adjustments on loans in

portfolio hedge accounting 14,894 14,894 – – – –

Investments in associates and

joint ventures 46 46 – – – –

Property & equipment 17 17 – – – –

Other assets 56 56 – – 2 –

TOTAL ASSETS 154,000 123,559 26,953 3,459 9,677 29

LIABILITIES

Amounts due to banks 3,530 – 1,698 – 1,782 50

Financial liabilities at fair value

through the income statement 1,190 – – – 1,020 170

Derivatives 24,780 – 24,780 – 1,841 –

Current Tax Liability 31 – – – – 31

Deferred Tax Liability 116 – – – – 116

Debt securities 112,180 – – – 63,378 48,802

Funds entrusted 7,557 – – – 2,347 5,210

Subordinated debts 31 – – – – 31

Other liabilities 99 – – – – 99

TOTAL LIABILITIES 149,514 – 26,478 – 70,368 54,509


(ARTICLE 436 CRR)

CARRYING VALUES AS

REPORTED IN PUBLISHED FINANCIAL

STATEMENTS AND FOR

REGULATORY CONSOLI-

DATION

CARRYING VALUES OF

ITEMS SUBJECT TO


CARRYING VALUES OF

ITEMS SUBJECT TO

COUNTER-PARTY CREDIT

RISK FRAMEWORK

CARRYING VALUES OF

ITEMS SUBJECT TO

SECURITI-SATION

FRAMEWORK

CARRYING VALUES OF

ITEMS SUBJECT TO


CARRYING VALUES OF ITEMS NOT

SUBJECT TO CAPITAL RE-

QUIREMENTS OR SUBJECT TO

DEDUCTION OF CAPITAL




45

Main sources of differencesbetween regulatory exposure amounts and carrying values

(EU LI2)


(ARTICLE 436 CRR)

MAIN SOURCES OF DIFFERENCES BETWEEN REGULATORY EXPOSURE

AMOUNTS AND CARRYING VALUES (EU LI2)

31/12/2017

Asset carrying value amount under scope of

regulatory consolidation (as per template LI1) 139,997 113,842 22,874 3,281 4,633

Liabilities carrying value amount under regulatory

scope of consolidation (as per template LI1) 81,252 – 22,239 – 62,508

TOTAL NET AMOUNT UNDER REGULATORY SCOPE OF CONSOLIDATION 58,745 113,842 635 3,281 –57,875

Off-balance sheet amounts before CCF after

provisions 12,743 12,510 – 233 –

Differences due to application of the overall net

FX position 57,791 – – – 57,791

Differences due to application of Mark-to-Market

Method and contractual netting for CCR 2,516 – 2,516 – –

Differences between financial statements and

exposure value due to valuation and netting 1,108 –30 – – –

EXPOSURE AMOUNTS CONSIDERED FOR REGULATORY PURPOSES 132,903 126,322 3,151 3,514 –84

TOTAL

ITEMS SUBJECT TO


ITEMS SUBJECT TO

COUNTER-PARTY


ITEMS

SUBJECT TOSECURITI-

SATION FRAMEWORK

ITEMS SUBJECT TO


46

31/12/2016

Asset carrying value amount under scope of

regulatory consolidation (as per template LI1) 153,971 123,559 26,953 3,459 9,677

Liabilities carrying value amount under regulatory

scope of consolidation (as per template LI1) 95,005 – 26,478 – 70,368

TOTAL NET AMOUNT UNDER REGULATORY SCOPE OF CONSOLIDATION 58,966 123,559 475 3,459 –60,691

Off-balance sheet amounts before CCF after

provisions 14,005 13,743 – 262 –

Differences due to application of the overall net

FX position 60,578 – – – 60,578

Differences due to application of Mark-to-Market

Method and contractual netting for CCR 4,313 – 4,313 – –

Differences between financial statements and

exposure value due to valuation and netting 7,829 –7 – – –

Difference due to treatment of collateral 11,541 11,541 – – –

EXPOSURE AMOUNTS CONSIDERED FOR REGULATORY PURPOSES 157,232 148,836 4,788 3,721 –113

TOTAL

ITEMS SUBJECT TO


ITEMS SUBJECT TO

COUNTER-PARTY


ITEMS

SUBJECT TOSECURITI-

SATION FRAMEWORK

ITEMS SUBJECT TO



(ARTICLE 436 CRR)

MAIN SOURCES OF DIFFERENCES BETWEEN REGULATORY EXPOSURE

AMOUNTS AND CARRYING VALUES (EU LI2)

47SCOPE OF APPLICATION

(ARTICLE 436 CRR)

EXPLANATIONS OF DIFFERENCES BETWEEN ACCOUNTING AND

REGULATORY EXPOSURE (EU LIA)

Explanations of differencesbetween accounting and

regulatory exposure (EU LIA)

The consolidation scope for the purpose of calculating Regulatory Capital is equal to the consolidation scope under IFRS. The main differences between the carrying value of assets under the scope of regulatory consolidation and the exposure amounts considered for regulatory purposes can be explained by the inclusion of the off-balance sheet liabilities in the exposure amounts for regulatory purposes, the exclusion of items that are capital deducted and the different valuation of derivatives due to netting rules and collateral. The market risk framework for regulatory purposes consists for BNG Bank only of the standardised approach for foreign exchange risk. In table LI1 the column for the market risk framework show all transactions with a foreign currency component. After eliminating the transactions denominated in Euro this results in table LI2 in a minor short position for both year-end 2017 and year-end 2016.

48SCOPE OF APPLICATION

(ARTICLE 436 CRR)

OUTLINE OF THE DIFFERENCES IN THE SCOPES OF CONSOLIDATION

(EU LI3)

NAME OF THE ENTITY

BNG Gebieds-

ontwikkeling

BV

Hypotheek-

fonds voor

overheids-

personeel BV

(HVO)

METHOD OF ACCOUNTING

CONSOLIDATION

Fully

consolidation

Fully

consolidation

METHOD OF REGULATORY CONSOLIDATION

FULLY CONSOLIDATION

X

X

PROPORTIONAL CONSOLIDATION

NEITHER CONSOLIDATED NOR DEDUCTED DEDUCTED

DESCRIPTION OF THE ENTITY

To directly or indirectly

provide (venture) capital

to public authorities and

to directly or indirectly

parti cipate in and/or

cooperate with projects,

either with or on behalf

of public authorities or

institutions affiliated with

public authorities.

The financing of mortgage

loans taken out by civil

servants in the employ

of an affiliated public or

semi-public institution

with which a cooperation

agreement has been

reached.

Outline of the differences in the scopes of consolidation

(EU LI3)

49

Balance sheet reconciliation

BNG Bank’s capitalization is well above the fully-loaded capital requirements laid down in the Capital Requirements Directive IV (CRD IV). The capital structure consists mainly of common equity. The other part consists of additional Tier 1 instruments.

SHARE CAPITALThe authorised capital is divided into 100 million shares with a nominal value of EUR 2.50 each, of which 55,690,720 shares have been issued and fully paid up. The number of shares in circulation remained unchanged during the financial year. There are no issued shares that are not fully paid up. BNG Bank and its subsidiaries hold no company shares. None of the shares carry preferential rights, nor are they subject to restrictions. There are no options that can be exercised to obtain entitlement to the issue of shares.

Equity attributable to the shareholders includes reserves which consist of a revaluation reserve, the cash flow hedge reserve, a reserve for fair value increases as well as retained earning from previous years. This equity amounts to EUR 4,221 million at end of 2017 and a full breakdown is included in the Annual report (pp. 161-163).

HYBRID CAPITALThe bank’s hybrid capital amounts to EUR 733 million. In 2017 no additional hybrid capital was issued. Hybrid capital concerns perpetual loans involving an annual non-cumulative discretionary payment on the outstanding principal amount, subject to compulsory amortisation in the event that the CET1 ratio falls below 5.125%. The payment qualifies as dividend under IFRS and is charged to the Other reserves. The deductibility of this payment for corporate income tax purposes has led to a public debate and the announcement of an enquiry by the European Commission into this subject in relation to potentially incompatible state aid. If the European Commission makes a negative recommendation, this could mean that BNG Bank will be required to repay the tax benefits and/or that future deductibility will no longer be permitted.

BALANCE SHEET RECONCILIATIONOWN FUNDS (ARTICLE 437 CRR)

Own funds (article 437 CRR)

50

The instrument is structured in line with CRR requirements and the EBA guidelines and qualifies as additional Tier 1 capital. BNG Bank has the unilateral contractual option of repaying the perpetual capital instruments prematurely on the sixth coupon due date (in May 2021 and 2022) and subsequently every year on the coupon due date.

The tables below show the structure of the regulatory capital. The tables present the capital in the transitional situation and the capital after full phasing-in (2018).

31/12/2017

CAPITAL CAPITAL (FULLY (TRANSITIONAL) PHASED IN) IFRS EQUITY

Paid-up capital 139 139 139

Share premium 6 6 6

Retained earnings from previous years 3,221 3,221 3,221

Unappropriated profit 393

Accumulated other comprehensive income

– Cash flow hedge reserve 193 193 193

– Revaluation reserve 268 268 268

COMMON EQUITY TIER 1 (CET1) CAPITAL BEFORE REGULATORY ADJUSTMENTS 3,827 3,827 4,220

Adjustments to CET1 capital as a result of prudential filters:

– Cash flow hedge reserve –193 –193

– Cumulative gains and losses arising from the bank’s own credit risk related

to derivatives liabilities –6 –6

– Own credit risk for Financial liabilities at fair value through the

income statement –9 –9

– Value adjustments due to the prudential valuation requirements –8 –8

Deduction of capital for securitisation positions eligible as alternatives for a

risk weight of 1250% –25 –25

Transitional adjustments to CET1 capital:

– Intangible assets –2 –2

– Unrealised losses in the revaluation reserve 9 –

– Unrealised gains in the revaluation reserve –60 –

CET1 CAPITAL 3,533 3,584

Additional Tier 1 capital: 733 733 733

TIER 1 CAPITAL 4,266 4,317

TOTAL EQUITY 4,953


51BALANCE SHEET RECONCILIATIONOWN FUNDS (ARTICLE 437 CRR)

31/12/2016

CAPITAL CAPITAL (FULLY (TRANSITIONAL) PHASED IN) IFRS EQUITY

Paid-up capital 139 139 139

Share premium 6 6 6

Retained earnings from previous years 2,961 2,961 2,961

Unappropriated profit 369

Accumulated other comprehensive income

– Cash flow hedge reserve 3 3 3

– Revaluation reserve 275 275 275

COMMON EQUITY TIER 1 (CET1) CAPITAL BEFORE REGULATORY ADJUSTMENTS 3,384 3,384 3,753

Adjustments to CET1 capital as a result of prudential filters:

– Cash flow hedge reserve –3 –3

– Cumulative gains and losses arising from the bank’s own

credit risk related to derivatives liabilities –19 –19

– Own credit risk for Financial liabilities at fair value

through the income statement –24 –24

– Value adjustments due to the prudential valuation requirements –8 –8

Deduction of capital for securitisation positions eligible as alternatives for a

risk weight of 1250% –29 –29

Transitional adjustments to CET1 capital:

– Unrealised losses in the revaluation reserve 25 –

– Unrealised gains in the revaluation reserve –126 –

CET1 CAPITAL 3,200 3,301

Additional Tier 1 capital: 733 733 733

TIER 1 CAPITAL 3,933 4,034

TOTAL EQUITY 4,486

PRUDENTIAL FILTERSBNG Bank applies the following prudential filters to the CET1 capital:– The cash flow hedge reserve is eliminated in its entirety.– The benefits arising from own credit risk in derivatives transactions are eliminated in their

entirety.– The benefits arising from ‘own credit risk’ in relation to obligations classified as Financial

liabilities at fair value through the income statement are eliminated in their entirety.– Due to the regulations on prudent valuation, an adjustment is calculated in relation to the

balance sheet valuation of assets and liabilities that are carried at fair value.

52

DEDUCTIBLE ITEMSBNG Bank opts to reduce the CET1 capital by two securitisation positions that are eligible for 1250% solvency weighting.

ADJUSTMENTS IN CRD IV/CRR TRANSITION PHASEThe portion of unrealised gains and losses from the revaluation reserve for Financial assets available-for-sale included in the CET1 capital was 80% in 2017 (2016: 60%).


53

N.V. BANK NEDERLANDSEGEMEENTEN

1 Issuer

2 Unique identifier (eg CUSIP,

ISIN or Bloomberg identifier

for private placement)

3 Governing law(s) of the

instrument

REGULATORY TREATMENT

4 Transitional CRR rules

5 Post-transitional CRR

rules

6 Eligible at solo/(sub-)

consolidated/solo &

(sub-)consolidated

7 Instrument type (types

to be specified by

each jurisdiction)

8 Amount recognised in

regulatory capital

(Currency in million,

as of most recent

reporting date)

9 Nominal amount of

instrument

9A Issue price


N.V. Bank Nederlandse

Gemeenten

Laws of the

Netherlands

Common Equity Tier 1

Common Equity Tier 1

Solo & (sub-)consoli dated

Ordinary share

EUR 145

EUR 139

n/a


Gemeenten

XS1311037433

Laws of the

Netherlands

Additional Tier 1

Additional Tier 1


Perpetual Capital

Security

EUR 424

EUR 424

100% for 1st tranche at

16/11/2015 (a 2nd tranche

was issued on 15/12/2015 on

the same terms with a price

of 100.61%)


Gemeenten

XS1453520378

Laws of the

Netherlands

Additional Tier 1

Additional Tier 1


Perpetual Capital Security

EUR 309

EUR 309

100% for 1st tranche

at 28/07/2016 (two follow-

up tranches were issued

in second half of 2016 on

same terms at 100.34%

and 99.72% respectively)

CAPITAL INSTRUMENTS’ MAIN FEATURES TEMPLATEOWN FUNDS (ARTICLE 437 CRR)

Capital instruments’ main features template

54



9B Redemption price

10 Accounting classification

11 Original date of issuance

12 Perpetual or dated

13 Original maturity date

14 Issuer call subject to prior

supervisory approval

15 Optional call date,

contingent call dates, and

redemption amount

16 Subsequent call dates,

if applicable

COUPONS/DIVIDENDS

17 Fixed or floating

dividend/coupon

18 Coupon rate and any

related index

19 Existence of a dividend

stopper

20A Fully discretionary,

partially discretionary

or mandatory (in terms

of timing)

20B Fully discretionary,

partially discretionary or

mandatory (in terms of

amount)

21 Existence of step up or

other incentive to

redeem

22 Noncumulative or

cumulative

23 Convertible or

non-convertible


n/a

Shareholders’ equity

23 December 1914

Perpetual

No maturity

No

n/a

n/a

Floating

n/a

n/a

Mandatory

Fully discretionary

n/a

Noncumulative

Nonconvertible

Subject to write down

Equity

16 November 2015

Perpetual

No maturity

Yes

16 May 2021 and every

interest payment date

thereafter, Tax and/or

regulatory event call,

Redemption at prevailing

principal amount

Interest payment date

(16 May)

Fixed

3.622%, resettable on 16

May 2021 and every 5 years

afterwards equal to

prevailing 5-year Mid-Swap

Rate plus initial margin

n/a

Mandatory

Fully discretionary

No

Noncumulative

Nonconvertible

Subject to write down

Equity

28 July 2016

Perpetual

No maturity

Yes


interest payment date

thereafter, Tax and/or

regulatory event call,

Redemption at prevailing

principal amount

Interest payment date

(16 May)

Fixed

3.277%, resettable on


5 years afterwards equal to

prevailing 5-year Mid-Swap

Rate plus initial margin

n/a

Mandatory

Fully discretionary

No

Noncumulative

Nonconvertible


55



24 If convertible, conversion

trigger(s)

25 If convertible, fully or

partially

26 If convertible, conversion

rate

27 If convertible, mandatory

or optional conversion

28 If convertible, specify

instrument type

convertible into

29 If convertible, specify issuer

of instrument it converts into

30 Write-down features

31 If write-down, write-down

trigger(s)

32 If write-down, fully or

partially

33 If write-down, permanent or

temporary

34 If temporary write-down,

description of write-up

mechanism

35 Position in subordination

hierarchy in liquidation

(specify instrument type

immediately senior to

instrument)

36 Non-compliant transitioned

features

37 If yes, specify non-compliant

features

n/a

n/a

n/a

n/a

n/a

n/a

No

n/a

n/a

n/a

n/a

Additional Tier 1

instruments

No

n/a

n/a

n/a

n/a

n/a

n/a

Yes

CET1 ratio < 5.125%

Partially

Temporary

Pro rata with other

Discretionary Temporary

Write-down Instruments,

subject to MDA and

Maximum Write-up

Amount

Tier 2 instruments

No

n/a

n/a

n/a

n/a

n/a

n/a

Yes

CET1 ratio < 5.125%

Partially

Temporary

Pro rata with other

Discretionary Temporary

Write-down Instruments,

subject to MDA and

Maximum Write-up

Amount

Tier 2 instruments

No


56TRANSITIONAL OWN FUNDS DISCLOSURE TEMPLATEOWN FUNDS (ARTICLE 437 CRR)

Transitional own funds disclosure template

COMMON EQUITY TIER 1 CAPITAL: INSTRUMENTS AND RESERVES

1 Capital instruments and the related share

premium accounts

of which: Ordinary shares

of which: Share premium

of which: Instrument type 3

2 Retained earnings

3 Accumulated other comprehensive

income (and any other reserves)

3A Funds for general banking risk

4 Amount of qualifying items referred to in

Article 484 (3) and the related share

premium accounts subject to phase out

from CET1

Public sector capital injections

grandfathered until 1 january 2018

5 Minority interests (amount allowed in

consolidated CET1)

5A Independently reviewed interim profits

net of any foreseeable charge or dividend

6 COMMON EQUITY TIER 1 (CET1) CAPITAL BEFORE REGULATORY ADJUSTMENTS


(A) AMOUNT AT

31/12/2016

145

139

6

–

2,961

278

–

–

–

–

3,384

(A) AMOUNT AT

31/12/2017

145

139

6

–

3,221

461

–

–

–

–

3,827

(B) REGULATION (EU) NO 575/2013 ARTICLE REFERENCE

26 (1), 27, 28, 29,

EBA list 26 (3)

EBA list 26 (3)

EBA list 26 (3)

EBA list 26 (3)

26 (1) (c)

26 (1)

26 (1) (f)

486 (2)

483 (2)

84, 479, 480

26 (2)

(C) AMOUNTS SUBJECT TO PRE-REGU LA TION (EU) NO 575/2013 TREATMENT OR PRE SCRIBED RESIDUAL AMOUNT OF REGULATION (EU) 575/2013

57



COMMON EQUITY TIER 1 (CET1) CAPITAL: REGULATORY ADJUSTMENTS

7 Additional value adjustments

(negative amount)

8 Intangible assets (net of related tax liability)

(negative amount)

9 Empty set in the EU

10 Deferred tax assets that rely on future

profitability excluding those arising from

temporary difference (net of related tax

liability where the conditions in Article

38 (3) are met) (negative amount)

11 Fair value reserves related to gains or

losses on cash flow hedges

12 Negative amounts resulting from the

calculation of expected loss amounts

13 Any increase in equity that results from

securitised assets (negative amount)

14 Gains or losses on liabilities valued at fair

value resulting from changes in own credit

standing

15 Defined-benefit pension fund assets

(negative amount)

16 Direct and indirect holdings by an

institution of own CET1 instruments

(negative amount)

17 Direct, indirect and synthetic holdings of

the CET1 instruments of financial sector

entities where those entities have

reciprocal cross holdings with the

institution designed to inflate artificially

the own funds of the institution (negative

amount)


(A) AMOUNT AT

31/12/2016

–8

–

–

–

–3

–

–

–43

–

–

–

(A) AMOUNT AT

31/12/2017

–8

–2

–

–

–193

–

–

–15

–

–

–


34, 105

36 (1) (b), 37,

472 (4)

36 (1) (c), 38,

472 (5)

33 (a)

36 (1) (d), 40, 159,

472 (6)

32 (1)

33 (1) (b) (c)

36 (1) (e), 41,

472 (7)

36 (1) (f), 42,

472 (8)

36 (1) (g), 44,

472 (9)


TRANSITIONAL OWN FUNDS DISCLOSURE TEMPLATEOWN FUNDS (ARTICLE 437 CRR)

58





entities where the institution does not

have a significant investment in those

entities (amount above 10% threshold

and net of eligible short positions)

(negative amount)



entities where the institution has a

significant investment in those entities

(amount above 10% threshold and net of

eligible short positions) (negative amount)


20A Exposure amount of the following items

which qualify for a RW of 1250%, where

the institution opts for the deduction

alternative

20B of which: qualifying holdings outside the

financial sector (negative amount)

20C of which: securitisation positions

(negative amount)

20D of which: free deliveries (negative amount)

21 Deferred tax assets arising from

temporary difference (amount above 10%

threshold, net of related tax liability

where the conditions in Article 38 (3)

are met) (negative amount)

22 Amount exceeding the 15% threshold

(negative amount)


(A) AMOUNT AT

31/12/2016

–

–

–

–29

–

–29

–

–

–

(A) AMOUNT AT

31/12/2017

–

–

–

–25

–

–25

–

–

–


36 (1) (h), 43, 45,

46, 49 (2) (3), 79,

472 (10)

36 (1) (i), 43, 45, 47,

48 (1) (b), 49 (1) to

(3), 79, 470, 472 (11)

36 (1) (k)

36 (1) (k) (i),

89 to 91

36 (1) (k) (ii)

243 (1) (b)

244 (1) (b)

258

36 (1) (k) (iii),

379 (3)

36 (1) (c), 38,

48 (1) (a), 470,

472 (5)

48 (1)



59



23 of which: direct and indirect holdings by

the institution of the CET1 instruments

of financial sector entities where the

institution has a significant investment

in those entities


25 of which: deferred tax assets arising from

temporary difference

25A Losses for the current financial year

(negative amount)

25B Foreseeable tax charges relating to CET1

items (negative amount)

26 Regulatory adjustments applied to

Common Equity Tier 1 in respect of

amounts subject to pre-CRR treatment

26A Regulatory adjustments relating to

unrealised gains and losses pursuant to

Articles 467 and 468

26B Amount to be deducted from or added

to Common Equity Tier 1 capital with

regard to additional filters and deductions

required pre CRR

27 Qualifying AT1 deductions that exceeds

the AT1 capital of the institution

(negative amount)

28 TOTAL REGULATORY ADJUSTMENTS TO COMMON EQUITY TIER 1 (CET1)

29 COMMON EQUITY TIER 1 (CET1) CAPITAL


(A) AMOUNT AT

31/12/2016

–

–

–

–

–

–100

–100

–

–

–184

3,200

(A) AMOUNT AT

31/12/2017

–

–

–

–

–

–51

–51

–

–

–294

3,533


36 (1) (i), 48 (1) (b),

470, 472 (11)

36 (1) (c), 38, 48 (1)

(a), 470, 472 (5)

36 (1) (a), 472 (3)

36 (1) (l)

481

36 (1) (j)


516

51


6 As a consequence of CRR the revaluation reserve is gradually phased in, in 2017 80% of the unrealized gains and losses from

this revaluation reserve are included. Since BNG Bank has fully included its net gain in its CET1, 20% of this gain is deducted

as a regulatory adjustment (EUR 51 mln in 2017). When CRR is fully phased in, this deduction would no longer be necessary

and this would lead to a 0,4% increase of the capital ratios.

60



ADDITIONAL TIER 1 (AT1) CAPITAL: INSTRUMENTS


premium accounts

31 of which: classified as equity under

applicable accounting standards

32 of which: classified as liabilities under

applicable accounting standards

33 Amount of qualifying items referred to

in Article 484 (4) and the related share


from AT1



34 Qualifying Tier 1 capital included in

consolidated AT1 capital (including

minority interest not included in row 5)

issued by subsidiaries and held by third

parties

35 of which: instruments issued by

subsidiaries subject to phase-out

36 ADDITIONAL TIER 1 (AT1) CAPITAL BEFORE REGULATORY ADJUSTMENTS

ADDITIONAL TIER 1 (AT1) CAPITAL: REGULATORY ADJUSTMENTS


institution of own AT1 instruments

(negative amount)

38 Holdings of the AT1 instruments of

financial sector entities where those

entities have reciprocal cross holdings

with the institution designed to inflate

artificially the own funds of the institution

(negative amount)


(A) AMOUNT AT

31/12/2016

733

733

–

–

–

–

–

733

–

–

(A) AMOUNT AT

31/12/2017

733

733

–

–

–

–

–

733

–

–


51, 52

486 (3)

483 (3)

85, 86, 480

486 (3)

52 (1) (b), 56 (a), 57,

475 (2)

56 (b), 58, 475 (3)



61



39 Direct, indirect and synthetic holdings

of the AT1 instruments of financial sector

entities where the institution does not

have a significant investment in those

entities (amount above 10% threshold

and net of eligible short positions)

(negative amount)


of the AT1 instruments of financial sector

entities where the institution has a

significant investment in those entities

(amount above 10% threshold and net of

eligible short positions) (negative amount)

41 Regulatory adjustments applied to

Additional Tier 1 capital in respect of


and transitional treatments subject to

phase-out as prescribed in Regulation (EU)

No 585/2013 (ie. CRR residual amounts)

41A Residual amounts deducted from

Additional Tier 1 capital with regard to

deduction from Common Equity Tier 1

capital during the transitional period

pursuant to article 472 of Regulation (EU)

No 575/2013

41B Residual amounts deducted from


deduction from Tier 2 capital during the

transitional period pursuant to article 475

of Regulation (EU) No 575/2013

41C Amounts to be deducted from added to


additional filters and deductions required

pre-CRR


(A) AMOUNT AT

31/12/2016

–

–

–

–

–

–

(A) AMOUNT AT

31/12/2017

–

–

0

–

–

–


56 (c), 59, 60, 79,

475 (4)

56 (d), 59, 79,

475 (4)

472, 473(3)(a),

472 (4), 472 (6),

472 (8) (a), 472 (9),

472 (10) (a),

472 (11) (a)

477, 477 (3),

477 (4) (a)

467, 468, 481



62



42 Qualifying T2 deductions that exceed

the T2 capital of the institution

(negative amount)

43 TOTAL REGULATORY ADJUSTMENTS TO ADDITIONAL TIER 1 (AT1) CAPITAL

44 ADDITIONAL TIER 1 (AT1) CAPITAL

45 ADDITIONAL TIER 1 (AT1) CAPITAL

TIER 2 (T2) CAPITAL: INSTRUMENTS AND PROVISIONS


premium accounts

47 Amount of qualifying items referred to

in Article 484 (5) and the related share


from T2



48 Qualifying own funds instruments

included in consolidated T2 capital

(including minority interest and AT1

instruments not included in rows 5 or 34)

issued by subsidiaries and held by

third party

49 of which: instruments issued by

subsidiaries subject to phase-out

50 Credit risk adjustments

51 TIER 2 (T2) CAPITAL BEFORE REGULATORY ADJUSTMENT


(A) AMOUNT AT

31/12/2016

–

–

733

3,933

–

–

–

–

–

–

–

(A) AMOUNT AT

31/12/2017

–

0

733

4,266

–

–

–

–

–

–

–


56 (e)

62, 63

486 (4)

483 (4)

87, 88, 480

486 (4)

62 (c) & (d)



63




institution of own T2 instruments and

subordinated loans (negative amount)

53 Holdings of the T2 instruments and

subordinated loans of financial sector

entities where those entities have

reciprocal cross holdings with the

institutions designed to inflate artificially

the own funds of the institution

(negative amount)


of the T2 instruments and subordinated

loans of financial sector entities where

the institution does not have a significant

investment in those entities (amount

above 10% threshold and net of eligible

short positions) (negative amount)

54A Of which new holdings not subject to

transitional arrangements

54B Of which holdings existing befor

1 January 2013 and subject to transitional

arrangements


of the T2 instruments and subordinated

loans of financial sector entities where

the institution has a significant investment

in those entities (net of eligible short

positions) (negative amounts)

56 Regulatory adjustments applied to Tier 2

in respect of amounts subject to pre-CRR

treatment and transitional treatments

subject to phase out as prescribed in

Regulation (EU) No 575/2013 (i.e. CRR

residual amounts)


(A) AMOUNT AT

31/12/2016

–

–

–

–

–

–

–

–

(A) AMOUNT AT

31/12/2017

–

–

–

–

–

–

–

–


63 (b) (i), 66 (a), 67,

477 (2)

66 (b), 68, 477 (3)

66 (c), 69, 70, 79,

477 (4)

66 (d), 69, 79,

477 (4)



64



56A Residual amounts deducted from Tier 2

capital with regard to deduction from

Common Equity Tier 1 capital during the



56B Residual amounts deducted from Tier 2

capital with regard to deduction from

Additional Tier 1 capital during the



56C Amounts to be deducted from or added

to Tier 2 capital with regard to additional

filters and deductions required pre-CRR

57 TOTAL REGULATORY ADJUSTMENTS TO TIER 2 (T2) CAPITAL

58 TIER 2 (T2) CAPITAL

59 TOTAL CAPITAL (TC = T1 + T2)

59A Risk weighted assets in respect of


and transitional treatments subject to

phase out as prescribed in Regulation (EU)

No 575/2013 (i.e. CRR residual amount)

Of which:… items not deducted from CET1

(Regulation (EU) No 575/2013 residual

amounts) (items to be detailed line by line,

e.g. Deferred tax assets that rely on future

profitability net of related tax liability,

indirect holdings of own CET1, etc)


(A) AMOUNT AT

31/12/2016

–

–

–

–

–

3,933

–

–

(A) AMOUNT AT

31/12/2017

–

–

–

–

–

4,266

–

–


472, 472(3) (a),

472 (4), 472 (6),

472 (8), 472 (9),

472 (10) (a),

472 (11) (a)

475, 475 (2) (a),

475 (3), 475 (4) (a)

467, 468, 481

472, 472 (5), 472 (8)

(b), 472 (10) (b),

472 (11) (b)



65



Of which:…items not deducted from AT1

items (Regulation (EU) No 575/2013

residual amounts) (items to be detailed

line by line, e.g. Reciprocal cross holdings

in T2 instruments, direct holdings of

non-significant investments in the capital

of other financial sector entities, etc.)

Items not deducted from T2 items

(Regulation (EU) No 575/2013 residual

amounts) (items to be detailed line by

line, e.g. Indirect holdings of own T2

instruments, indirect holdings of non-

significant investments in the capital of

other financial sector entities, indirect

holdings of significant investments in

the capital of other financial sector

entities etc)

60 TOTAL RISK-WEIGHTED ASSETS

CAPITAL RATIOS AND BUFFERS

61 Common Equity Tier 1 (as a percentage

of total risk exposure amount)

62 Tier 1 (as a percentage of total risk

exposure amount)

63 Total capital (as a percentage of total risk

exposure amount)


(A) AMOUNT AT

31/12/2016

–

–

12,327

26.0%

31.9%

31.9%

(A) AMOUNT AT

31/12/2017

–

–

11,641

30.4%

36.7%

36.7%


475, 475 (2) (b), 475

(2) ©, 475 (4) (b)

477, 477 (2) (b), 477

(2) (c), 477 (4) (b)

92 (2) (a), 465

92 (2) (b), 465

92 (2) (c)


–0.4%6

–0.4%6

–0.4%6


6 As a consequence of CRR the revaluation reserve is gradually phased in, in 2017 80% of the unrealized gains and losses from

this revaluation reserve are included. Since BNG Bank has fully included its net gain in its CET1, 20% of this gain is deducted

as a regulatory adjustment (EUR 51 mln in 2017). When CRR is fully phased in, this deduction would no longer be necessary

and this would lead to a 0,4% increase of the capital ratios.

66



64 Institution specific buffer requirement

(CET1 requirement in accordance with

article 92 (1) (a) plus capital conservation

and countercyclical buffer requirements

plus a systemic risk buffer, plus

systemically important institution buffer

expressed as a percentage of total risk

exposure amount)

65 of which: capital conservation buffer

requirement

66 of which: countercyclical buffer

requirement

67 of which: systemic risk buffer requirement

67A of which: Global Systemically Important

Institution (G-SII) or Other Systemically

Important Institution (O-SII) buffer

68 Common Equity Tier 1 available to meet

buffers (as a percentage of risk exposure

amount)

69 (non-relevant in EU regulation)



AMOUNTS BELOW THE THRESHOLDS FORDEDUCTION (BEFORE RISK-WEIGHTING)

72 Direct and indirect holdings of the capital

of financial sector entities where the

institution does not have a significant


below 10% threshold and net of eligible

short positions)


(A) AMOUNT AT

31/12/2016

5.375%

0.625%

–

–

0.25%

26.0%

–

–

–

–

(A) AMOUNT AT

31/12/2017

6.250%

1.250%

–

–

0.50%

30.4%

–

–

–

–


CRD 128, 129, 140

CRD 131

CRD 128

36 (1) (h), 45, 46,

472 (10)

56 (c), 59, 60, 475

(4), 66 (c), 69, 70,

477 (4)



67



73 Direct and indirect holdings of the CET1

instruments of financial sector entities

where the institution has a significant


below 10% threshold and net of eligible

short positions)


75 Deferred tax assets arising from

temporary difference (amount below 10%

threshold , net of related tax liability

where the conditions in Article 38 (3)

are met)

APPLICABLE CAPS ON THE INCLUSION OF PROVISIONS IN TIER 2

76 Credit risk adjustments included in T2

in respect of exposures subject to

standardised approach (prior to the

application of the cap)

77 Cap on inclusion of credit risk adjustments

in T2 under standardised approach

78 Credit risk adjustments included in T2 in

respect of exposures subject to internal

rating-based approach (prior to the

application of the cap)

79 Cap for inclusion of credit risk

adjustments in T2 under internal

ratings-based approach

CAPITAL INSTRUMENTS SUBJECT TO PHASE-OUT ARRANGEMENTS (ONLY APPLICABLE BETWEEN 1 JAN 2014 AND 1 JAN 2022)

80 Current cap on CET1 instruments subject

to phase-out arrangements


(A) AMOUNT AT

31/12/2016

–

–

–

–

–

–

–

–

(A) AMOUNT AT

31/12/2017

–

–

–

–

–

–

–

–


36 (1) (i), 45, 48,

470, 472 (11)

36 (1) (c), 38, 48,

470, 472 (5)

62

62

62

62

484 (3), 486 (2)

& (5)



68



81 Amount excluded from CET1 due to cap

(excess over cap after redemptions and

maturities)

82 Current cap on AT1 instruments subject


83 Amount excluded from AT1 due to cap


maturities)

84 Current cap on T2 instruments subject


85 Amount excluded from T2 due to cap


maturities)

(A) AMOUNT AT

31/12/2016

–

–

–

–

–

(A) AMOUNT AT

31/12/2017

–

–

–

–

–


484 (3), 486 (2)

& (5)

484 (4), 486 (3)

& (5)

484 (4), 486 (3)

& (5)

484 (5), 486 (4)

& (5)

484 (5), 486 (4)

& (5)



69

Capital and solvency

DEFINITIONS Regulatory capital relates to the capital requirements under the Basel framework. For Pillar 1 the capital requirement is based on the aggregated risk-weighted assets (RWA) for the three major risk types (credit, operational and market risk). BNG Bank employs the ‘Standardised Approach’ to calculate the RWAs.

In addition to the regulatory required capital BNG Bank calculates economic capital (EC) for Pillar 2 purposes. Economic capital covers all risks in our risk taxonomy, for which capital is deemed to be the mitigating instrument to cover unexpected losses. It is used for internal risk measurement and management. It is the amount of capital we deem adequate to achieve a sufficient level of protection against large unexpected losses that could result from extreme market conditions or events.

GOVERNANCEThe Executive Board is responsible for determining the policy with respect to capital. This is laid down in a capital adequacy statement and management plan. Next, the Executive Board is responsible for the allocation of capital. Decision making is prepared by the Capital Policy and Financial Regulations Committee. This committee comprises all relevant stakeholders: the executive board, Public Finance, Treasury, Capital Management, Risk Management and Finance and Control.

DEVELOPMENTSAs at December 2017, the phase-in CRD IV Common Equity Tier 1 (CET1), Tier 1 and total capital ratios were respectively 30%, 37% and 37%. All capital ratios were well above regulatory minimum requirements. BNG Bank’s capital position strengthened compared to 31 December 2016 driven by profit accumulation. BNG Bank is required in 2018 to meet a minimum CET1 ratio of 8.875%, composed of a SREP requirement of 6.25% (4.5% Pillar 1 requirement and 1.75% Pillar 2 requirement), a phased-in systemic risk buffer (SrB) of 0.75% and a capital conservation buffer (CCB) of 1.875%. The SrB is expected to increase by 0.25% next year to its final level of 1% in 2019. The CCB will increase by

CAPITAL AND SOLVENCYCAPITAL REQUIREMENTS

(ARTICLE 438 CRR)

Capital requirements (article 438 CRR)

70

0.625% next year to its final level of 2.5% in 2019. BNG Bank amply meets the requirements. The MDA trigger level for BNG Bank is 8.875% of CET1 capital. Based on full phase-in of the SrB and CCB the fully loaded MDA trigger level is expected to increase to 9.75%.

In 2011, BNG Bank lowered its dividend distribution policy to 25% in order to meet the additional capital requirements introduced by Basel III. Given that clarity on the capital requirements is still pending (see subsection on regulatory framework) BNG Bank is not changing this policy now, but expects to update it in 2018 and present it to the General Meeting of Shareholders early 2019. That having said, BNG Bank proposes to increase the dividend distribution to 37.5% for the year 2017. This is supported by the solid performance on the ratio’s per year-end 2017 and the high net profit over the fiscal year 2017. Further support is given by the satisfactory outcomes of both the 2017 EBA Stress Test on interest rate risk and the scenarios that were used in the recovery plan.

CAPITAL MANAGEMENTThe primary objective of the capital management strategy is to ensure that internal as well as external capital adequacy requirements are met at all times and sufficient capital is available to support the bank’s strategy.

31/12/2017 31/12/2016

MINIMUM MINIMUM REQUIRED REQUIRED SOLVENCY EXTERNALLY PRESENT EXTERNALLY PRESENT

CRD IV/CRR (TRANSITIONAL)

Tier 1 capital 1,135 4,266 1,094 3,933

Total capital ratio 9.75% 37% 8.875% 32%

– Pillar I 8% 8%

– Combined Buffer Requirement 1.75% 0.875%

Common Equity Tier 1 capital 728 3,533 663 3,200

Common Equity Tier 1 ratio 6.25% 30% 5.375% 26%

– Pillar I 4.5% 4.5%


CRD IV/CRR (FULLY PHASED IN)

Tier 1 capital 1,339 4,317 1,418 4,034

Total capital ratio 11.5% 37% 11.5% 33%

– Pillar I 8% 8%


Common Equity Tier 1 capital 931 3,584 986 3,301

Common Equity Tier 1 ratio 8% 31% 8% 27%

– Pillar I 4.5% 4.5%



(ARTICLE 438 CRR)

71

The capital management strategy builds on the bank’s risk appetite and its business plans. Besides, expectations and requirements of external stakeholders (e.g. regulators, investors, rating agencies, shareholders), the bank’s capitalization relative to the market, market developments and the feasibility of capital management actions are taken into account.

The capitalization policy is incorporated in the so-called ICAAP. Key to this policy is the capital management plan, which determines the level and composition of the capital based on the risks to be insured by that capital. In the ICAAP, regulatory as well as economic capital is taken into account. As part of the ICAAP a number of stress scenarios is executed in order to determine the adequacy and robustness of the capitalization. Next to the level of capitalization, the ICAAP determines the allocation per relevant type of risk.

On an ongoing basis, capital adequacy is measured and monitored against target capital ratios. These target levels are derived from the bank’s risk appetite and strategy and quantified by the ICAAP. The allocation is derived from the ICAAP. This process ensures that the bank is operating in line with its risk appetite.

REGULATORY FRAMEWORKThe European Commission issued in November 2016 draft texts to amend CRD IV, CRR and BRRD. The legislative process is still ongoing with an expected adoption in 2018. In the context of capital, the leverage ratio and the Minimum Requirement for own funds and Eligible Liabilities (MREL) requirement are the main important subjects for BNG Bank.

The CRR introduces a non-risk based leverage ratio which would be monitored until 2017 and further refined and calibrated before becoming a binding measure as from 2018. As this binding measure is part of CRR 2, the details have not been finalised yet. Discussions are still ongoing over the required level, potentially depending on significance, and a proportional treatment of promotional banks. Developments in this respect are being monitored. BNG Bank’s capital planning is based on the 3% level communicated to date and reaffirmed by Basel IV (see below). As of December 2017, BNG Bank meets this target.

The BRRD provides authorities with more comprehensive and effective measures to deal with failing banks. The bail-in framework of the BRRD has been applicable since January 2016. The bail-in framework introduced an additional loss-absorbing measure, MREL. The definite requirements, in terms of both level and eligible instruments, have not been established yet. Next, the MREL requirement will be an institution specific requirement determined by the Single Resolution Board (SRB). As such, any future requirement will depend both on final regulations as well as on the assessment of the SRB. The Single Resolution Board (SRB) is responsible for preparing the resolution plan for BNG Bank. The SRB has not concluded its plan yet.

If the to be determined MREL requirement cannot be met with existing instruments, BNG Bank will likely use the new category of unsecured debt introduced by an – to be transposed in national law – EU harmonised approach on the priority ranking of bank bond holders in insolvency and in resolution to meet these requirements. The developments have been closely monitored during 2017 and BNG Bank will continue to do so in 2018.


(ARTICLE 438 CRR)

72

Commonly referred to as Basel IV, the Basel Committee on Banking Supervision has issued in December 2017 post crisis reforms. While introducing changes to the Standardised Approach, the framework aims specifically to enhance the reliability and comparability of risk-weighted capital ratios under the Internal Model approach. As such, the changes will impact the capital position of BNG Bank but are not expected to impact it in a material way. The treatment of sovereign exposures is not part of Basel IV. Revisions to this approach are part of a discussion paper. As sovereign exposures form a significant part of BNG Bank’s exposures, any changes to the treatment of these exposures will have a significant impact on BNG Bank’s capital ratios. Developments in this area will be monitored closely.


(ARTICLE 438 CRR)

73OVERVIEW OF RWA (EU OV1)

Overview of RWA (EU OV1)

CAPITAL REQUIREMENTS

(ARTICLE 438 CRR)

74

31/12/2017 30/09/2017 31/12/2017 30/09/2017

RWA MINIMUM CAPITAL REQUIREMENT

CREDIT RISK (EXCLUDING CCR) 8,374 8,387 670 671

Of which standardised approach (SA) 8,374 8,387 670 671

Of which the foundation IRB (FIRB) – – – –

Of which the advanced IRB (AIRB) – – – –

Of which Equity IRB under the simple

risk-weighted approach or the IMA – – – –

COUNTERPARTY CREDIT RISK 1,221 1,239 98 99

Of which mark-to-market – – – –

Of which original exposure – – – –

Of which the standardised approach 11 6 1 0

Of which internal model method (IMM) – – – –

Of which risk exposure amount for contributions

to the default fund of a CCP – – – –

Of which CVA 1,210 1,233 97 99

SETTLEMENT RISK – – – –

SECURITISATION EXPOSURES IN BANKING

BOOK (AFTER THE CAP) 1,095 1,200 88 96

Of which IRB approach (RBA) – – – -

Of which IRB Supervisory Formula Approach (SFA) – – – -

Of which internal assessment approach (IAA) – – – -

Of which Standardised approach (SA) 1,095 1,200 88 96

MARKET RISK 0 137 0 11

Of which Standardised approach (SA) 0 137 0 11

Of which IMA – – – –

LARGE EXPOSURES – – – –

OPERATIONAL RISK 951 752 76 60

Of which basic indicator approach – – – –

Of which standardised approach (SA) 951 752 76 60

Of which advanced measurement approach – – – –

Amounts below the thresholds for deduction

(subject to 250% risk weight) – – – –

FLOOR ADJUSTMENT – – – –

TOTAL 11,641 11,715 932 937

The table below shows an overview of total RWA (risk weighted assets) with the corresponding minimum capital requirements.

OVERVIEW OF RWA (EU OV1)CAPITAL REQUIREMENTS

(ARTICLE 438 CRR)

75OVERVIEW OF RWA (EU OV1)

31/12/2016 30/09/2016 31/12/2016 30/09/2016

RWA MINIMUM CAPITAL REQUIREMENT

CREDIT RISK (EXCLUDING CCR) 8,707 9,069 697 726

Of which standardised approach (SA) 8,707 9,069 697 726

Of which the foundation IRB (FIRB) – – – –

Of which the advanced IRB (AIRB) – – – –

Of which Equity IRB under the simple

risk-weighted approach or the IMA – – – –

COUNTERPARTY CREDIT RISK 1,452 1,455 116 116

Of which mark-to-market – – – –

Of which original exposure – – – –

Of which the standardised approach 1 0 0 0

Of which internal model method (IMM) – – – –

Of which risk exposure amount for contributions

to the default fund of a CCP – – – –

Of which CVA 1,451 1,455 116 116

SETTLEMENT RISK – – – –

SECURITISATION EXPOSURES IN BANKING

BOOK (AFTER THE CAP) 1,303 1,201 104 96

Of which IRB approach (RBA) - - - -

Of which IRB Supervisory Formula Approach (SFA) - - - -

Of which internal assessment approach (IAA) - - - -

Of which Standardised approach (SA) 1,303 1,201 104 96

MARKET RISK 113 0 9 0

Of which Standardised approach (SA) 113 0 9 0

Of which IMA – – – –

LARGE EXPOSURES – – – –

OPERATIONAL RISK 752 764 60 61

Of which basic indicator approach – – – –

Of which standardised approach (SA) 752 764 60 61

Of which advanced measurement approach – – – –

Amounts below the thresholds for deduction

(subject to 250% risk weight) – – – –

FLOOR ADJUSTMENT – – – –

TOTAL 12,327 12,489 986 999

CAPITAL REQUIREMENTS

(ARTICLE 438 CRR)

76

In the application of article 442 and 453 CRR templates and tables in this section provide further quantitative insight into the credit risk profile of BNG Bank. This first starts with some different perspectives on the overall portfolio of BNG Bank before concentrating on the non-performing and forborne exposures, the credit risk mitigation measures that are applied and the effects on the RWA that should be considered for capitalization purposes. However, first some more context is provided on the definitions applied with respect to the credit quality of assets.

Credit risk and credit risk mitigation (article 442 CCR

and 453 CCR)

CREDIT RISK AND CREDIT RISK

MITIGATION (ARTICLE 442 AND

453 CCR)

77CREDIT QUALITY ASSETS (EU CRB-A)CREDIT RISK AND CREDIT RISK


453 CCR)

Credit quality assets (EU CRB-A)

FORBORN EXPOSURESForbearance concerns credit agreements whose credit conditions have been amended in the debtor’s favour as a result of the debtor’s precarious financial position, so as to enable it to fulfill its obligations.

NON-PERFORMING AND IMPAIRED EXPOSURESNon-performing exposures are exposures:− whose contractual conditions have been breached by the debtor and/or payment arrears

(‘past due’) exceeding 90 days (‘default’); and/or− in respect of which the debtor is not expected to be able to continue fulfilling its future

payment obligations (in full) (‘unlikely to pay’); and/or− that are individually impaired.

The term ‘past due’ refers to the payment arrears commencing at the moment when the debtor has not paid (in full) by the date on which payment was due under the contract.

An exposure classified as non-performing can once again be regarded as performing if all the following conditions are met:− the debtor once again complies with all contractual terms of the exposure (no default); and− the debtor’s situation has improved to the extent that the debtor is able to meet payment

obligations according to an existing or adapted payment profile (‘likely to pay’); and− the debtor has no arrears exceeding 90 days.

Impaired exposures are exposures that are individually impaired. The term ‘impairment’ refers to write-offs on the items carried at fair value on the balance sheet, and loans for which an individual provision was made. Exposures included under the IBNI provision are not classified as impaired exposures. Likewise, off-balance sheet exposures are not classified as impaired either.

LOANS AND ADVANCES PROVISIONING POLICYBNG Bank employs a number of triggers that may lead to an individual loan loss provision:− an internal rating of 14 of higher, or− payment arrears and/or a breach of the contractual terms exceeding 90 days (‘default’) and/

or the debtor is no longer expected to meet its payment obligations in full (‘unlikely to pay’).

The individual facility only relates to loans and advances subject to solvency requirements. Loans and advances that are not subject to solvency requirements are deemed to be free of credit risk on account of guarantees, collateral or by virtue of the status of the counterparty,

78

such as the Dutch local authorities. Furthermore, the bank has a collective provision based on a so-called Incurred But Not Identified (IBNI) model. For loans and advances and off-balance exposures subject to solvency requirements, this model calculates a provision based on factors such as exposure and the debtor’s rating. Lastly, for loans and advances that are solvency-free due to a local authority guarantee, the model calculates a provision on the basis of a premium for operational risk. Both provisions fall under the regulatory specific credit risk adjustment.

CREDIT QUALITY ASSETS (EU CRB-A)CREDIT RISK AND CREDIT RISK


453 CCR)

79TOTAL AND AVERAGE NET AMOUNT OF EXPOSURES (EU CRB-B)CREDIT RISK AND CREDIT RISK


453 CCR)

Total and average net amountof exposures (EU CRB-B)

31/12/2017 31/12/2016

NET VALUE OF NET VALUE OF EXPOSURES AT AVERAGE NET EXPOSURES AT AVERAGE NET THE END OF EXPOSURE OF THE END OF EXPOSURE OF THE PERIOD THE PERIOD THE PERIOD THE PERIOD

Central governments or central banks 10,125 20,386 14,946 15,843

Regional governments or local authorities 36,495 36,742 37,404 37,813

Public sector entities 2,808 2,963 3,114 3,116

Multilateral Development Banks 733 862 877 852

International Organisations 730 968 1,217 1,218

Institutions 492 10,020 12,135 15,770

Corporates 61,426 61,859 61,981 62,175

– Of which: 0% risk weighted 51,163 51,442 51,740 51,950

Secured by mortgages on immovable property 172 183 199 210

Exposures in default 17 86 112 156

Covered bonds 1,278 1,471 1,819 1,920

Claims with a short-term credit assessment – – – –

Collective investments undertakings (CIU) 30 30 25 40

Equity 47 45 46 47

Securitisation positions 3,539 3,587 3,750 3,219

Other items 11,969 12,422 14,960 17,763

TOTAL CREDIT RISK EXPOSURE (SA) 129,861 151,624 152,585 160,142

– Of which: Small & Medium Enterprises (SMEs) 14,318 14,512 14,670 14,786

The exposure value to institutions at year-end 2017 is significantly different compared to year-end 2016. This is due to changes in the calculation of the original exposure amount related to derivatives and collateral. For the determination of the replacement cost both collateral posted and received that would be netted under an eligible netting agreement is taken into account in the original exposure amount. Whereas, prior year-end 2017, for determining the original exposure amount only derivatives transactions were considered and collateral posted and received was reported as a financial collateral deduction.

80GEOGRAPHICAL BREAKDOWN OF EXPOSURES (EU CRB-C)CREDIT RISK AND CREDIT RISK


453 CCR)

Geographical breakdown ofexposures (EU CRB-C)

31/12/2017

REST TOTAL NETHER- OTHER EURO REST OF OF THE EXPOSURE LANDS COUNTRIES EUROPE WORLD VALUE

Central governments or central banks 5,140 4,964 – 21 10,125

Regional governments or local authorities 36,043 452 – – 36,495

Public sector entities 2,122 595 91 – 2,808

Multilateral Development Banks – 733 – – 733

International Organisations – 730 – – 730

Institutions 12 480 – – 492

Corporates 58,964 784 1,678 – 61,426

– Of which: 0% risk weighted 50,335 179 649 – 51,163

Secured by mortgages on immovable property 172 – – – 172

Exposures in default 17 – – – 17

Covered bonds 578 169 531 – 1,278

Claims with a short-term credit assessment – – – – –

Collective investments undertakings (CIU) – 30 – – 30

Equity 47 – – – 47

Securitisation positions 2,846 652 41 – 3,539

Other items 11,936 33 – – 11,969

TOTAL CREDIT RISK EXPOSURE (SA) 117,877 9,622 2,341 21 129,861

81

31/12/2016

REST TOTAL NETHER- OTHER EURO REST OF OF THE EXPOSURE LANDS COUNTRIES EUROPE WORLD VALUE

Central governments or central banks 9,926 4,903 117 – 14,946

Regional governments or local authorities 36,760 644 – – 37,404

Public sector entities 2,175 939 – – 3,114

Multilateral Development Banks – 877 – – 877

International Organisations – 1,217 – – 1,217

Institutions 1,513 2,679 5,993 1,950 12,135

Corporates 59,314 944 1,723 – 61,981

– Of which: 0% risk weighted 50,849 229 662 – 51,740

Secured by mortgages on immovable property 199 – – – 199

Exposures in default 112 – – – 112

Covered bonds 648 838 333 – 1,819

Claims with a short-term credit assessment – – – – 0

Collective investments undertakings (CIU) – 25 – – 25

Equity 46 – – – 46

Securitisation positions 2,975 727 48 – 3,750

Other items 14,959 1 – – 14,960

TOTAL CREDIT RISK EXPOSURE (SA) 128,627 13,794 8,214 1,950 152,585

GEOGRAPHICAL BREAKDOWN OF EXPOSURES (EU CRB-C)CREDIT RISK AND CREDIT RISK


453 CCR)

82CONCENTRATION OF EXPOSURES BY INDUSTRY OR COUNTERPARTY

TYPES (EU CRB-D)



453 CCR)

Concentration of exposuresby industry or counterparty

types (EU CRB-D)

31/12/2017

OTHER NON- GENERAL CREDIT FINANCIAL FINANCIAL TOTAL GOVERN- INSTITU- CORPO- CORPO- HOUSE- EXPOSURE MENTS TIONS RATIONS RATIONS HOLDS OTHER VALUE

Central governments or central

banks 10,125 – – – – – 10,125

Regional governments or local

authorities 36,495 – – – – – 36,495

Public sector entities 2,808 – – – – – 2,808

Multilateral Development Banks – 733 – – – – 733

International Organisations 730 – – – – – 730

Institutions – 489 3 – – – 492

Corporates – – 2,287 55,332 3,807 – 61,426

– Of which: 0% risk weighted – – 1,168 47,221 2,774 – 51,163

Secured by mortgages on

immovable property – – – – 172 – 172

Exposures in default – – – 17 – – 17

Covered bonds – 1,202 76 – – – 1,278

Claims with a short-term credit

assessment – – – – – – 0

Collective investments

undertakings (CIU) – – 30 – – – 30

Equity – – – 47 – – 47

Securitisation positions – – 3,539 – – – 3,539

Other items – – – – – 11,969 11,969

TOTAL CREDIT RISK EXPOSURE (SA) 50,158 2,424 5,935 55,396 3,979 11,969 129,861

83CONCENTRATION OF EXPOSURES BY INDUSTRY OR COUNTERPARTY

TYPES (EU CRB-D)



453 CCR)

31/12/2016

OTHER NON- GENERAL CREDIT FINANCIAL FINANCIAL TOTAL GOVERN- INSTITU- CORPO- CORPO- HOUSE- EXPOSURE MENTS TIONS RATIONS RATIONS HOLDS OTHER VALUE


banks 14,946 – – – – – 14,946


authorities 37,404 – – – – – 37,404

Public sector entities 3,114 – – – – – 3,114


International Organisations 1,217 – – – – – 1,217

Institutions – 12,131 4 – – – 12,135

Corporates – – 2,108 56,015 3,858 – 61,981

– Of which: 0% risk weighted – – 1,208 47,771 2,761 – 51,740


immovable property – – – – 199 – 199

Exposures in default – – – 112 – – 112

Covered bonds – 1,212 607 – – – 1,819


assessment – – – – – – 0


undertakings (CIU) – – 25 – – – 25

Equity – – – 46 – – 46

Securitisation positions – – 3,750 – – – 3,750

Other items – – – – – 14,960 14,960

TOTAL CREDIT RISK EXPOSURE (SA) 56,681 14,220 6,494 56,173 4,057 14,960 152,585

84MATURITY OF EXPOSURES (EU CRB-E)CREDIT RISK AND CREDIT RISK


453 CCR)

Maturity of exposures (EU CRB-E)

31/12/2017 NET EXPOSURE VALUE

> 1 YEAR NO STATED ON DEMAND ≤ 1 YEAR ≤ 5 YEARS > 5 YEARS MATURITY TOTAL

Central governments or

central banks 2,996 – 1,167 5,962 – 10,125


authorities 714 3,583 6,049 20,807 – 31,153

Public sector entities 32 37 627 1,435 – 2,131

Multilateral Development Banks – – 256 477 – 733

International Organisations – 46 218 466 – 730

Institutions – 98 238 156 – 492

Corporates 527 2,884 8,531 42,997 – 54,939

– Of which: 0% risk weighted 195 2,118 7,155 38,508 – 47,976


immovable property – – – 172 – 172

Exposures in default 10 1 – 2 – 13

Covered bonds – 123 652 503 – 1,278


assessment – – – – – –


undertakings (CIU) – – – 30 – 30

Equity – 47 – – – 47

Securitisation positions – – – 3,306 – 3,306

Other items – 253 2,003 9,713 – 11,969

TOTAL CREDIT RISK EXPOSURE (SA) 4,279 7,072 19,741 86,026 – 117,118

85MATURITY OF EXPOSURES (EU CRB-E)CREDIT RISK AND CREDIT RISK


453 CCR)

31/12/2016 NET EXPOSURE VALUE

> 1 YEAR NO STATED ON DEMAND ≤ 1 YEAR ≤ 5 YEARS > 5 YEARS MATURITY TOTAL


central banks 6,417 116 1,271 6,142 – 13,946


authorities 678 3,930 5,602 21,408 – 31,618

Public sector entities 24 26 818 1,602 – 2,470

Multilateral Development Banks – 36 458 369 – 863

International Organisations – 110 796 311 – 1,217

Institutions – 11,695 231 209 – 12,135

Corporates 481 2,912 8,564 43,732 – 55,689

– Of which: 0% risk weighted 138 2,228 7,262 39,266 – 48,894


immovable property – – – 199 – 199

Exposures in default 21 6 – 77 – 104

Covered bonds – 177 857 785 – 1,819


assessment – – – – – 0


undertakings (CIU) – – – 25 – 25

Equity – 46 – – – 46

Securitisation positions – – – 3,488 – 3,488

Other items – 289 2,176 12,495 – 14,960

TOTAL CREDIT RISK EXPOSURE (SA) 7,621 19,343 20,773 90,842 – 138,579

The exposure values in this table is exclusive of off-balance exposure in contrast to the other tables. The total credit exposure is therefore lower than in the other tables.

86CREDIT QUALITY OF EXPOSURES BY EXPOSURE CLASSES AND

INSTRUMENTS (EU CR1-A)



453 CCR)

Credit quality of exposuresby exposure classes and instruments (EU CR1-A)

87CREDIT RISK AND CREDIT RISK


453 CCR)

31/12/2017

GROSS GROSS CARRYING CARRYING VALUES OF: CREDIT RISK VALUES OF: NON- SPECIFIC GENERAL ACCUMU- ADJUSTMENT DEFAULTED DEFAULTED CREDIT RISK CREDIT RISK LATED CHARGES OF EXPOSURES EXPOSURES ADJUSTMENT ADJUSTMENT WRITE-OFFS THE PERIOD NET VALUES


banks – 10,125 – – – – 10,125

Regional governments or

local authorities – 36,495 – – – – 36,495

Public sector entities – 2,808 – – – – 2,808


International Organisations – 730 – – – – 730

Institutions – 492 – – – – 492

Corporates 37 61,440 34 – – –8 61,443

– Of which: 0% risk weighted – 51,163 – – – – 51,163

– Of which: SMEs 10 14,314 6 – – – 14,318


immovable property – 172 – – – – 172

Exposures in default 37 – 20 – – –3 17

Covered bonds – 1,278 – – – – 1,278


assessment – – – – – – –


undertakings (CIU) – 30 – – – – 30

Equity – 47 – – – – 47

Securitisation positions – 3,539 – – – – 3,539

Other items – 11,969 – – – – 11,969

TOTAL CREDIT RISK EXPOSURE (SA) 37 129,858 34 – – –8 129,861

– Of which: Loans and advances 34 85,117 31 – – –8 85,120

– Of which: Debt securities – 16,890 – – – – 16,890

– Of which: Off-balance sheet

exposures 3 12,789 3 – – – 12,789

CREDIT QUALITY OF EXPOSURES BY EXPOSURE CLASSES AND




453 CCR)

31/12/2016



central banks – 14,946 – – – – 14,946


authorities – 37,404 – – – – 37,404

Public sector entities – 3,114 – – – – 3,114


International Organisations – 1,217 – – – – 1,217

Institutions – 12,135 – – – – 12,135

Corporates 138 61,997 42 – – –7 62,093

– Of which: 0% risk weighted – 51,740 – – – – 51,740

– Of which: SMEs 92 14,582 4 – – – 14,670


immovable property – 199 – – – – 199

Exposures in default 137 – 25 – – –7 112

Covered bonds – 1,819 – – – – 1,819


assessment – – – – – – –


undertakings (CIU) – 25 – – – – 25

Equity – 46 – – – – 46

Securitisation positions – 3,750 – – – – 3,750

Other items – 14,960 – – – – 14,960

TOTAL CREDIT RISK EXPOSURE (SA) 138 152,489 42 – – –7 152,585

– Of which: Loans and advances 130 98,334 –42 – – –7 98,505

– Of which: Debt securities – 18,586 – – – – 18,586

– Of which: Off-balance sheet

exposures 8 14,013 – – – – 14,021

CREDIT QUALITY OF EXPOSURES BY EXPOSURE CLASSES AND


89CREDIT QUALITY OF EXPOSURES BY INDUSTRY OR COUNTERPARTY

TYPES (EU CR1-B)



453 CCR)

Credit quality of exposures by industry or counterparty

types (EU CR1-B)

31/12/2017


General governments – 50,158 – – – – 50,158

Credit institutions – 2,424 – – – – 2,424

Other financial corporations – 5,936 1 – – –3 5,935

Non-financial corporations 32 55,390 26 – – –4 55,396

Households 5 3,981 7 – – –1 3,979

Other – 11,969 – – – – 11,969

TOTAL 37 129,858 34 – – –8 129,861

31/12/2016


General governments – 56,681 – – – – 56,681

Credit institutions – 14,220 – – – – 14,220

Other financial corporations 13 6,485 4 – – –7 6,494

Non-financial corporations 120 56,083 30 – – – 56,173

Households 5 4,060 8 – – – 4,057

Other – 14,960 – – – – 14,960

TOTAL 138 152,489 42 – – –7 152,585

90CREDIT QUALITY OF EXPOSURES BY GEOGRAPHY (EU CR1-C)CREDIT RISK AND CREDIT RISK


453 CCR)

Credit quality of exposuresby geography (EU CR1-C)

31/12/2017


Netherlands 37 117,873 33 – – –8 117,877

Other Euro countries – 9,623 1 – – – 9,622

Rest of Europe – 2,341 – – – – 2,341

Rest of the world – 21 – – – – 21

TOTAL 37 129,858 34 – – –8 129,861

31/12/2016


Netherlands 138 128,530 41 – – 3 128,627

Other Euro countries – 13,795 1 – – –10 13,794

Rest of Europe – 8,214 – – – – 8,214

Rest of the world – 1,950 – – – – 1,950

TOTAL 138 152,489 42 – – –7 152,585

91AGEING OF PAST-DUE EXPOSURES (EU CR1-D)CREDIT RISK AND CREDIT RISK


453 CCR)

Ageing of past-due exposures(EU CR1-D)

31/12/2017 GROSS CARRYING VALUES

> 30 DAYS > 60 DAYS > 90 DAYS > 180 DAYS ≤ 30 DAYS ≤ 60 DAYS ≤ 90 DAYS ≤ 180 DAYS ≤ 1 YEAR > 1 YEAR

Debt securities – – – – – –

Loans and advances 1 – – – 2 8

Off-balance sheet exposures – – – – – –

TOTAL 1 – – – 2 8

31/12/2016 GROSS CARRYING VALUES

> 30 DAYS > 60 DAYS > 90 DAYS > 180 DAYS ≤ 30 DAYS ≤ 60 DAYS ≤ 90 DAYS ≤ 180 DAYS ≤ 1 YEAR > 1 YEAR

Debt securities – – – – – –

Loans and advances – – – – 1 9


TOTAL – – – – 1 9

At 31 december 2017 EUR 3 million of the EUR 10 million past due exposures more than 90 days is not impaired. This is due to the expectation that this amount will be received in full.

92NON-PERFORMING AND FORBORNE EXPOSURES (EU CR1-E)CREDIT RISK AND CREDIT RISK


453 CCR)

Non-performing and forborne exposures

(EU CR1-E)

31/12/2017

GROSS CARRYING VALUES OF PERFORMING AND NON-PERFORMING EXPOSURES

OF WHICH PERFORMING BUT PAST DUE > 30 DAYS OF WHICH OF WHICH AND PERFORMING NON- OF WHICH OF WHICH OF WHICH ≤ 90 DAYS FORBORNE PERFORMING DEFAULTED IMPAIRED FORBORNE

Debt securities 17,119 – – 14 14 14 –

Loans and advances 102,330 – 235 38 38 29 6

Off-balance sheet exposures 12,782 – – – – – –

TOTAL 132,231 – 235 52 52 43 6

31/12/2017 COLLATERALS AND ACCUMULATED IMPAIRMENT AND PROVISIONS AND FINANCIAL GUARANTEES NEGATIVE FAIR VALUE ADJUSTMENTS DUE TO CREDIT RISK RECEIVED

ON ON-NON PERFORMING PERFORMING ON EXPOSURES ON-NON EXPOSURES ON-NON OF WHICH PERFORMING OF WHICH PERFORMING OF WHICH PERFORMING FORBORN EXPOSURES FORBORN EXPOSURES FORBORN EXPOSURES EXPOSURES

Debt securities –259 – – – – –

Loans and advances –72 –1 –20 – – –


TOTAL –331 –1 –20 – – –



453 CCR)

31/12/2016

GROSS CARRYING VALUES OF PERFORMING AND NON-PERFORMING EXPOSURES

OF WHICH PERFORMING BUT PAST DUE > 30 DAYS OF WHICH OF WHICH AND PERFORMING NON- OF WHICH OF WHICH OF WHICH ≤ 90 DAYS FORBORNE PERFORMING DEFAULTED IMPAIRED FORBORNE

Debt securities 18,876 – – 16 16 16 –

Loans and advances 105,072 – 177 130 130 129 13

Off-balance sheet exposures 14,006 – – 8 8 – –

TOTAL 137,954 – 177 154 154 145 13

31/12/2016 COLLATERALS AND ACCUMULATED IMPAIRMENT AND PROVISIONS AND FINANCIAL GUARANTEES NEGATIVE FAIR VALUE ADJUSTMENTS DUE TO CREDIT RISK RECEIVED

ON ON-NON PERFORMING PERFORMING ON EXPOSURES ON-NON EXPOSURES ON-NON OF WHICH PERFORMING OF WHICH PERFORMING OF WHICH PERFORMING FORBORN EXPOSURES FORBORN EXPOSURES FORBORN EXPOSURES EXPOSURES

Debt securities –311 – – – – –

Loans and advances –87 –1 –25 –2 – 22

Off-balance sheet exposures – – – – – 7

TOTAL –398 –1 –25 –2 – 29

NON-PERFORMING AND FORBORNE EXPOSURES (EU CR1-E)

94CHANGES IN STOCK OF GENERAL AND SPECIFIC CREDIT RISK

ADJUSTMENTS (EU CR2-A)



453 CCR)

Changes in stock of general and specific credit risk

adjustments (EU CR2-A)

ACCUMULATED SPECIFIC CREDIT RISK ADJUSTMENT

OPENING BALANCE 31-12-2015 49

Increases due to amounts set aside for estimated loan losses during the period 4

Decreases due to amounts reversed for estimated loan losses during the period –7

Decreases due to amounts taken against accumulated credit risk adjustments –4

Transfers between credit risk adjustments –

Impact of exchange rate differences –

Business combinations, including acquisitions and disposals of subsidiaries –

Other adjustments – CLOSING BALANCE 31/12/2016 42

Recoveries on credit risk adjustments recorded directly to the statement of profit or loss –

Specific credit risk adjustments directly recorded to the statement of profit or loss –

OPENING BALANCE 31/12/2016 42

Increases due to amounts set aside for estimated loan losses during the period 3

Decreases due to amounts reversed for estimated loan losses during the period –7

Decreases due to amounts taken against accumulated credit risk adjustments –4

Transfers between credit risk adjustments –

Impact of exchange rate differences –

Business combinations, including acquisitions and disposals of subsidiaries –

Other adjustments –

CLOSING BALANCE 31/12/2017 34

Recoveries on credit risk adjustments recorded directly to the statement of profit or loss 3

Specific credit risk adjustments directly recorded to the statement of profit or loss –

The EUR 34 million (2016: EUR 42 million) incurred loss provision comprises EUR 20 million (2016: EUR 26 million) of individual provisions and EUR 14 million (2016: EUR 16 million) of a collective provision (IBNI).

95CHANGES IN STOCK OF DEFAULTED AND IMPAIRED LOANS AND

DEBT SECURITIES (EU CR2-B)



453 CCR)

Changes in stock of defaulted and impaired loans and

debt securities (EU CR2-B)

GROSS CARRYING VALUE DEFAULTED EXPOSURES

CLOSING BALANCE 31-12-2015 212

Loans and debt securities that have defaulted or impaired since the last reporting date 99

Returned to non-defaulted status –58

Amounts written off –

Other changes –116 CLOSING BALANCE 31/12/2016 138

Loans and debt securities that have defaulted or impaired since the last reporting date 11

Returned to non-defaulted status –104

Amounts written off –

Other changes –8

CLOSING BALANCE 31/12/2017 37

The strong decrease in non-performing exposure is largely attributable to the fact that one of the bank’s clients – which had a non-performing exposure of EUR 91 million at the end of 2016 – became performing in 2017, following the restructuring and partial redemption of his loan portfolio.

Furthermore, it should be noted that the closing balance reported in template EU CR2-B is different from the reported defaulted exposure in template CR1-E. This can be attributed to different definitions that are applied. A securitisation exposure which is recognized as a non- performing in CR1-E is not recognized in the stock of defaulted loans and debt securities because this exposure qualifies for a 1250% risk weighting. BNG Bank uses the option to offset these items against the CET1 capital and does therefore not include in table EU-CR2-B.

96CREDIT RISK MITIGATION TECHNIQUES – OVERVIEW (EU CR3)CREDIT RISK AND CREDIT RISK


453 CCR)

Credit risk mitigation techniques – overview

(EU CR3)

31/12/2017

EXPOSURES EXPOSURES UNSECURED – EXPOSURES EXPOSURES SECURED CARRYING EXPOSURES TO SECURED BY SECURED BY BY CREDIT AMOUNT BE SECURED COLLATERAL GUARANTEES DERIVATIVES

Total loans and advances 85,116 47,774 66 47,708 –

Total debt securities 13,555 1,413 – 1,413 –

Total securitisation 3,539 – – – –

Total off balance sheet exposure 12,516 3,239 5 3,234 –

Total other exposure 15,135 10 – 10 –

TOTAL EXPOSURES 129,861 52,436 71 52,365 –

Of which defaulted 17 – – – –

31/12/2016

EXPOSURES EXPOSURES UNSECURED – EXPOSURES EXPOSURES SECURED CARRYING EXPOSURES TO SECURED BY SECURED BY BY CREDIT AMOUNT BE SECURED COLLATERAL GUARANTEES DERIVATIVES

Total loans and advances 98,328 60,117 11,581 48,536 –

Total debt securities 15,079 1,915 – 1,915 –

Total securitisation 3,750 – – – –

Total off balance sheet exposure 13,750 3,013 54 2,959 –

Total other exposure 21,678 – – – –

TOTAL EXPOSURES 152,585 65,045 11,635 53,410 –

Of which defaulted 112 – – – –

97STANDARDISED APPROACH – CREDIT RISK EXPOSURE AND CREDIT

RISK MITIGATION (CRM) EFFECTS (EU CR4)



453 CCR)

Standardised approach – credit risk exposure and

credit risk mitigation (CRM) effects (EU CR4)

Guarantees provided by governments, WSW and WfZ are an important part in the determination of the credit risk profile of BNG Bank. Below tables show the effect of all CRM techniques. RWA density provides a synthetic metric on the portfolio that remains after the application of CRM techiniques.

31/12/2017 EXPOSURES BEFORE CCF EXPOSURES POST CCF RWAS AND AND CRM AND CRM RWA DENSITY

ON- OFF- ON- OFF- RWA BALANCE BALANCE BALANCE BALANCE RWA DENSITY


banks 10,125 1 54,372 393 – 0%


authorities 31,153 5,342 35,516 538 101 0%

Public sector entities 2,131 676 2,045 16 274 13%

Multilateral Development Banks 733 – 733 – – 0%

International Organisations 730 – 730 – – 0%

Institutions 492 – 29 – 11 38%

Corporates 54,939 6,488 6,939 234 6,375 89%


immovable property 172 – 45 – 45 100%

Exposures in default 13 3 13 – 14 108%

Covered bonds 1,278 – 1,278 – 135 11%




undertakings (CIU) 30 – 30 – 30 100%

Equity 47 – 47 – 47 100%

Securitisation positions 3,306 233 3,281 116 1,095 32%

Other items 11,969 – 11,969 – 25 0%

TOTAL 117,118 12,743 117,027 1,297 8,152 7%



453 CCR)

31/12/2016 EXPOSURES BEFORE CCF EXPOSURES POST CCF RWAS AND AND CRM AND CRM RWA DENSITY

ON- OFF- ON- OFF- RWA BALANCE BALANCE BALANCE BALANCE RWA DENSITY


banks 13,946 1,000 59,455 321 – 0%


authorities 31,618 5,786 36,083 667 106 0%

Public sector entities 2,470 644 2,185 – 287 13%

Multilateral Development Banks 863 14 863 3 – 0%

International Organisations 1,217 – 1,217 – – 0%

Institutions 12,135 – 84 – 11 13%

Corporates 55,689 6,292 6,613 300 6,146 89%


immovable property 199 – 57 – 57 100%

Exposures in default 104 8 104 – 104 100%

Covered bonds 1,819 – 1,819 – 244 13%




undertakings (CIU) 25 – 25 – 25 100%

Equity 46 – 46 – 46 100%

Securitisation positions 3,488 262 3,459 131 1,303 36%

Other items 14,960 – 14,960 – 60 0%

TOTAL 138,579 14,006 126,970 1,422 8,389 7%

STANDARDISED APPROACH – CREDIT RISK EXPOSURE AND CREDIT

RISK MITIGATION (CRM) EFFECTS (EU CR4)

99STANDARDISED APPROACH BEFORE RISK MITIGATION (EU CR5)CREDIT RISK AND CREDIT RISK


453 CCR)

Standardised approach before risk mitigation

(EU CR5)

31/12/2017

TOTAL OF EXPO- WHICH DE- SURE UN- 0% 2% 10% 20% 35% 50% 100% > 100% DUCTED VALUE RATED


banks 54,765 – – – – – – – – 54,765 54,765


local authorities 35,777 – – 219 – – 58 – – 36,054 36,043

Public sector entities 689 – – 1,372 – – – – – 2,061 1,970

Multilateral Development Banks 733 – – – – – – – – 733 733

International Organisations 730 – – – – – – – – 730 730

Institutions – – – 12 – 17 – – – 29 20

Corporates – – – 666 – 539 5,958 10 – 7,173 6,022


immovable property – – – – – – 45 – – 45 45

Exposures in default – – – – – – 13 1 – 14 –

Covered bonds – – 1,208 71 – – – – – 1,279 –


assessment – – – – – – – – – – –


undertakings (CIU) – – – – – – 30 – – 30 30

Equity – – – – – – 47 – – 47 47

Securitisation positions 43 – – 2,389 74 736 129 26 25 3,422 80

Other items 11,944 – – – – – 25 – – 11,969 11,969

TOTAL CREDIT RISK EXPOSURE 104,681 – 1,208 4,729 74 1,292 6,305 37 25 118,351 112,454



453 CCR)

31/12/2016

TOTAL OF EXPO- WHICH DE- SURE UN- 0% 2% 10% 20% 35% 50% 100% > 100% DUCTED VALUE RATED


banks 59,776 – – – – – – – – 59,776 59,776


local authorities 36,439 – – 255 – – 55 – – 36,749 36,725

Public sector entities 748 – – 1,437 – – – – – 2,185 2,185

Multilateral Development Banks 866 – – – – – – – – 866 866

International Organisations 1,217 – – – – – – – – 1,217 1,217

Institutions 51 3 – 14 – 17 – – – 85 71

Corporates – – – 581 – 605 5,728 – – 6,914 5,835


immovable property – – – – – – 57 – – 57 57

Exposures in default – – – – – – 104 – – 104 –

Covered bonds – – 1,201 618 – – – – – 1,819 –


assessment – – – – – – – – – – –


undertakings (CIU) – – – – – – 25 – – 25 25

Equity – – – – – – 46 – – 46 46

Securitisation positions 32 – – 2,555 99 599 243 62 29 3,619 112

Other items 14,894 – – – – – 66 – – 14,960 14,960

TOTAL CREDIT RISK EXPOSURE 114,023 3 1,201 5,460 99 1,221 6,324 62 29 128,422 121,875

STANDARDISED APPROACH BEFORE RISK MITIGATION (EU CR5)

101

Counterparty credit risk (article 439 CRR)

Counterparty credit risk means the risk that the counterparty to a transaction could default before the final settlement of the transaction’s cash flows. The exposure to counterparty credit risk pertains to exposures arising from derivatives, repurchase transactions, securities or commodities lending or borrowing transactions, long settlement transactions and margin lending transactions. This section provides different perspectives on this counterparty credit risk as it pertains to BNG Bank.

COUNTERPARTY CREDIT RISK

(ARTICLE 439 CRR)

Analysis of the counterpartycredit risk (CCR) exposure

by approach (EU CCR1)

The credit risk of derivative transactions is relatively small, despite the fact that principal amounts totalled EUR 224 billion at year-end 2017 (2016: EUR 240 billion). With the exception of currency derivatives, these contractual principal amounts merely serve as accounting quantities and do not reflect the size of cash flows or the risk associated with the derivatives. The credit equivalent of the derivatives portfolio serves as a more accurate indicator in this regard. The credit risk is expressed in terms of credit equivalents, in accordance with central bank guidelines. The credit equivalent consists of the market value plus an add-on for future credit risk. Contracts with a positive value – where contractual default by the counterparty would cause the bank to miss out on revenue – are relevant in this regard.

BNG Bank determines this value using the Mark-to-Market (MtM) method. The current replacement cost is calculated by including collateral received or posted. In addition, the principal amounts are multiplied by percentages based on the specific product and its maturity period in order to determine the potential credit risk (‘add-on’). The sum of these two values (credit equivalent) indicates the net exposure to credit risk.

ANALYSIS OF THE COUNTERPARTY CREDIT RISK (CCR) EXPOSURE BY

APPROACH (EU CCR1)

102ANALYSIS OF THE COUNTERPARTY CREDIT RISK (CCR) EXPOSURE BY

APPROACH (EU CCR1)


(ARTICLE 439 CRR)

31/12/2017

REPLACEMENT COST/ POTENTIAL CURRENT FUTURE MARKET CREDIT EAD POST NOTIONAL VALUE EXPOSURE EEPE MULTIPLIER CRM RWAS

Mark-to-market 1,061 1,528 2,589 1,316

Original exposure method – – –

Standardised approach – – –

IMM (for derivatives and SFT’s) – – – –

Financial collateral simple method

(for SFT’s) – –

Financial collateral comprehensive

method (for SFT’s) – –

VaR for SFT’s – –

TOTAL 1,316

31/12/2016

REPLACEMENT COST/ POTENTIAL CURRENT FUTURE MARKET CREDIT EAD POST NOTIONAL VALUE EXPOSURE EEPE MULTIPLIER CRM RWAS

Mark-to-market 2,822 1,896 3,167 1,612

Original exposure method – – –

Standardised approach – – –

IMM (for derivatives and SFT’s) – – – –

Financial collateral simple method

(for SFT’s) – –

Financial collateral comprehensive

method (for SFT’s) – –

VaR for SFT’s – –

TOTAL 1,612

103

Credit valuation adjustment(CVA) capital charge

(EU CCR2)

CREDIT VALUATION ADJUSTMENT (CVA) CAPITAL CHARGE (EU CCR2)COUNTERPARTY CREDIT RISK

(ARTICLE 439 CRR)

31/12/2017

EXPOSURE VALUE RWAS

Total portfolios subject to the advanced method – –

(i) VaR component – –

(ii) SVaR component – –

All portfolios subject to the standardised method 1,523 1,210

Based on the original exposure method – –

TOTAL SUBJECT TO THE CVA CAPITAL CHARGE 1,523 1,210

31/12/2016

EXPOSURE VALUE RWAS

Total portfolios subject to the advanced method – –

(i) VaR component – –

(ii) SVaR component – –

All portfolios subject to the standardised method 1,875 1,451

Based on the original exposure method – –

TOTAL SUBJECT TO THE CVA CAPITAL CHARGE 1,875 1,451

104

Standardised approach – CCR exposures by regulatory portfolio and risk (EU CCR3)

STANDARDISED APPROACH – CCR EXPOSURES BY REGULATORY

PORTFOLIO AND RISK (EU CCR3)


(ARTICLE 439 CRR)

31/12/2017

TOTAL OF EXPO- WHICH SURE UN- 0% 2% 10% 20% 50% 70% 75% 100% 150% OTHERS VALUE RATED



banks 59 – – – – – – – – – 59 59


local authorities 201 – – – – – – – – – 201 201

Public Sector Entities – – – 85 – – – – – – 85 85

Institutions – 562 – 598 925 – – – – – 2,085 180

Corporates – – – 5 – – – 716 – – 721 716

TOTAL 260 562 – 688 925 – – 716 – – 3,151 1,241

31/12/2016

TOTAL OF EXPO- WHICH SURE UN- 0% 2% 10% 20% 50% 70% 75% 100% 150% OTHERS VALUE RATED



banks 88 – – – – – – – – – 88 88


local authorities 239 – – – – – – – – – 239 239

Public Sector Entities – – – 107 – – – – – – 107 107

Institutions – 58 – 641 1,234 – – – – – 1,933 28

Corporates – – – 7 – – – 846 – – 853 848

TOTAL 327 58 – 755 1,234 – – 846 – – 3,220 1,310

105

Impact of netting and collateral held on exposure

values (EU CCR5-A)

IMPACT OF NETTING AND COLLATERAL HELD ON EXPOSURE

VALUES (EU CCR5-A)


(ARTICLE 439 CRR)

31/12/2017

GROSS POSITIVE FAIR VALUE NETTED OR NET CURRENT CARRYING NETTING CREDIT COLLATERAL NET CREDIT AMOUNT BENEFITS EXPOSURE HELD EXPOSURE

Derivatives 9,323 7,907 1,416 369 1,047

SFTs – – – – –

Cross-product netting – – – – –

TOTAL 9,323 7,907 1,416 369 1,047

31/12/2016

GROSS POSITIVE FAIR VALUE NETTED OR NET CURRENT CARRYING NETTING CREDIT COLLATERAL NET CREDIT AMOUNT BENEFITS EXPOSURE HELD EXPOSURE

Derivatives 15,559 12,690 2,869 1,776 1,093

SFTs – – – – –

Cross-product netting – – – – –

TOTAL 15,559 12,690 2,869 1,776 1,093

106

Composition of collateral for exposures to counterparty

credit risk (EU CCR5-B)

COMPOSITION OF COLLATERAL FOR EXPOSURES TO

COUNTERPARTY CREDIT RISK (EU CCR5-B)


(ARTICLE 439 CRR)

COLLATERAL USED IN COLLATERAL USED IN DERIVATIVE TRANSACTIONS SECURITIES FINANCE TRANSACTIONS

FAIR VALUE OF FAIR VALUE OF FAIR VALUE OF FAIR VALUE OF COLLATERAL COLLATERAL COLLATERAL COLLATERAL RECEIVED POSTED RECEIVED POSTED

TOTAL 31/12/2017 369 14,326 – –

TOTAL 31/12/2016 1,776 11,795 – –

At year-end 2017, the collateral posted amounted to EUR 14.3 billion (2016: EUR 11.8 billion). The deterioration of BNG Bank’s rating by three notches would increase this amount by EUR 10 million (2016: EUR 35 million). The strength of the bank’s liquidity position is sufficient to meet, and to absorb fluctuations in, higher collateral obligations.

107

Exposures to central counterparties (EU CCR8)

EXPOSURES TO CENTRAL COUNTERPARTIES (EU CCR8)COUNTERPARTY CREDIT RISK

(ARTICLE 439 CRR)

31/12/2017

EAD POST CRM RWAS

Exposures for trades at QCCPs (excluding initial margin and default fund

contributions); of which 562 11

(i) OTC derivatives 562 11

(ii) Exchange traded derivatives – –

(iii) SFT’s – –

(iv) Netting sets where cross-product netting has been approved – –

Segregated initial margin – –

Non-segregated initial margin – –

Prefunded default fund contributions – –

Alternative calculation of own funds requirements for exposures – –

TOTAL EXPOSURES TO QCCPS 562 11

31/12/2016

EAD POST CRM RWAS

Exposures for trades at QCCPs (excluding initial margin and default fund

contributions); of which 58 11

(i) OTC derivatives 58 11

(ii) Exchange traded derivatives – –

(iii) SFT’s – –

(iv) Netting sets where cross-product netting has been approved – –

Segregated initial margin – –

Non-segregated initial margin – –

Prefunded default fund contributions – –

Alternative calculation of own funds requirements for exposures – –

TOTAL EXPOSURES TO QCCPS 58 11

108

Encumbered and unencumbered financial assets

The encumbered and unencumbered assets in carrying and fair value amounts by broad categories of asset type.

ENCUMBERED AND UNENCUMBERED FINANCIAL ASSETSUNENCUMBERED ASSETS

(ARTICLE 443)

Unencumbered assets (article 443 CCR)

31/12/2017

CARRYING CARRYING AMOUNT OF FAIR VALUE OF AMOUNT OF FAIR VALUE OF ENCUMBERED ENCUMBERED UNENCUMBERED UNENCUMBERED ASSETS ASSETS ASSETS ASSETS ASSETS OF THE REPORTING INSTITUTION 17,303 122,722

Equity instruments – – – –

Debt securities 3,000 3,000 13,859 13,887

Loans and advances 14,303 87,955

Other assets – 20,908

31/12/2016

CARRYING CARRYING AMOUNT OF FAIR VALUE OF AMOUNT OF FAIR VALUE OF ENCUMBERED ENCUMBERED UNENCUMBERED UNENCUMBERED ASSETS ASSETS ASSETS ASSETS ASSETS OF THE REPORTING INSTITUTION 12,220 141,780

Equity instruments – – 25 25

Debt securities 254 254 18,310 18,333

Loans and advances 11,966 93,019

Other assets – 30,426

109

Collateral received by an institution, by broad

categories of product type

COLLATERAL RECEIVED BY AN INSTITUTION, BY BROAD CATEGORIES

OF PRODUCT TYPE

31/12/2017

FAIR VALUE FAIR VALUE OF OF COLLATERAL ENCUMBERED RECEIVED OR OWN COLLATERAL RECEIVED DEBT SECURITIES OR OWN DEBT ISSUED AVAILABLE SECURITIES ISSUED FOR ENCUMBRANCE

COLLATERAL RECEIVED BY THE REPORTING INSTITUTION – 2,680

Equity instruments – –

Debt securities – 2,311

Other collateral received – 369

Own debt securities issued other than own covered bonds or ABSs – –

31/12/2016

FAIR VALUE FAIR VALUE OF OF COLLATERAL ENCUMBERED RECEIVED OR OWN COLLATERAL RECEIVED DEBT SECURITIES OR OWN DEBT ISSUED AVAILABLE SECURITIES ISSUED FOR ENCUMBRANCE

COLLATERAL RECEIVED BY THE REPORTING INSTITUTION – 1,776

Equity instruments – –

Debt securities – –

Other collateral received – 1,776

Own debt securities issued other than own covered bonds or ABSs – –

UNENCUMBERED ASSETS

(ARTICLE 443)

110

Carrying amount of encumbered assets/collateral

received and associated liabilities

CARRYING AMOUNT OF ENCUMBERED ASSETS/COLLATERAL

RECEIVED AND ASSOCIATED LIABILITIES

31/12/2017

ASSETS, COLLATERAL MATCHING RECEIVED AND LIABILITIES, OWN DEBT SECURITIES CONTINGENT ISSUED OTHER THAN LIABILITIES OR COVERED BONDS AND SECURITIES LENT ABSS ENCUMBERED

Carrying amount of selected financial liabilities 16,092 16,892

31/12/2016

ASSETS, COLLATERAL MATCHING RECEIVED AND LIABILITIES, OWN DEBT SECURITIES CONTINGENT ISSUED OTHER THAN LIABILITIES OR COVERED BONDS AND SECURITIES LENT ABSS ENCUMBERED

Carrying amount of selected financial liabilities 18,162 11,795

UNENCUMBERED ASSETS

(ARTICLE 443)

111

Narrative information on the importance of

asset encumbrance for an institution

NARRATIVE INFORMATION ON THE IMPORTANCE OF ASSET

ENCUMBRANCE FOR AN INSTITUTION

UNENCUMBERED ASSETS

(ARTICLE 443)

Encumbered assets are assets involving a pledge or claim and include loans deposited at the central bank, issued paper collateral for repurchase agreements and derivative contracts, re-issued paper collateral and collateralized buy-backs of BNG Bank issues. In times of funding and liquidity needs, encumbered financial assets are not freely disposable to be able to meet these needs in the short term.

Selected financial liabilities consist of derivative positions with a negative balance sheet value which are covered by paper collateral. Collateral received by BNG Bank comprises of debt securities issued by governments and financial corporations and is used for money market transactions. BNG Bank also pledged a portfolio of loans with the Central Bank for monetary purposes. Since most of the banks assets could serve as collateral, this may be further extended in the event of prolonged stress.

112

For the disclosure of market risk pursuant with policies and strategies, please refer to the chapter Risk management objectives and policies in the section ‘market risk’. Below table MR1 shows the components of own funds requirements under the standardised approach for market risk. Only temporary small foreign exchange positions for which it is not efficient to hedge the risks may result in a limited capital charge.

MARKET RISK (ARTICLE 445 CRR)

Market risk (article 445 CRR)

Market risk under the standardised approach

(EU MR1)

31/12/2017 31/12/2016

CAPITAL CAPITAL RWAS REQUIREMENT RWAS REQUIREMENT

OUTRIGHT PRODUCTS

Interest rate risk (general and specific) – – – –

Equity risk (general and specific) – – – –

Foreign exchange risk – – 113 9

Commodity risk – – – –

OPTIONS

Simplified approach – – – –

Delta-plus method – – – –

Scenario approach – – – –

Securitisation (specific risk) – – – –

TOTAL – – 113 9

MARKET RISK UNDER THE STANDARDISED APPROACH (EU MR1)

113

STARTING POINTSThe remuneration policy is compatible with the legal and policy frameworks for institutions established in the Netherlands. In 2017, the following laws and regulations were instrumental in determining the remuneration policy:– European and national financial supervision rules, including the Capital Requirements

Regulation, the Financial Supervision Act, the Regulation on Sound Remuneration Policies, the Remuneration Policy (Financial Enterprises) Act and the Work and Security Act;

– the Dutch Corporate Governance Code;– the Banking Code.In addition to satisfying legal and regulatory requirements, the remuneration policy also complies with the central government’s policy for state-owned enterprises.

REMUNERATION POLICY FOR THE EXECUTIVE BOARDThe current remuneration policy for Executive Board members was adopted by the General Meeting of Shareholders on 5 October 2016. This remuneration policy is applicable in its entirety to executives appointed after 1 January 2016. The existing employment contracts of executives appointed before that date are respected.

BNG Bank strives for terms of employment and a remuneration level for its Executive Board that are in line with the market. ‘In line with the market’ means determined through comparison with what is considered normal in the sector of the Dutch labour market relevant to BNG Bank. In order to make this comparison, a reference group was defined in consultation with the shareholders. The reference group is comprised of both public and private components. While the private group component takes the WNT standard as its reference, the public component was compiled in consultation between the BNG Bank Supervisory Board and shareholders. This public component has a weighting of 60% and the private component a weighting of 40%. The median in the reference group serves as the starting point for market conformity. Independent external advice is used to assist in comparing remuneration. In principle, the Supervisory Board reviews every four years whether developments in the reference group warrant modification of the Executive Board terms of employment.

The total remuneration of the Chair in 2016 will not exceed EUR 301,000. This upper limit for the remuneration is increased annually (from 2017 onwards) with the general increases in the Collective Labour Agreement for the Banking Industry. The primary remuneration for Executive Board members consists of 12 times the monthly salary plus holiday allowance.

REMUNERATION (ARTICLE 450 CRR)

Remuneration (article 450 CRR)

114

The employment contracts with the Executive Board members stipulate which provisions from the Collective Labour Agreement for the Banking Industry are applicable.

In addition, the provisions of the pension regulations of Stichting Pensioenfonds ABP (average salary system with personal contribution) apply to the Executive Board members. The retirement age is linked to the State Pension age. No compensation is provided to Executive Board members if the retirement age (statutory/for tax purposes) is raised further.

The employment contracts with Executive Board members specify appointment for a four-year period, with the term of the employment contract matching the period of appointment. This provision does not apply to individuals who are proposed for appointment from within BNG Bank and who already have a permanent contract.

No other severance payments than those provided for by the Dutch Work and Security Act (Wet werk en zekerheid) are agreed with Executive Board members. The severance pay will consequently never exceed the amount of the transition payment.

Deviation from the upper limit for remuneration and the other employment terms and conditions is only possible with the approval of the shareholders, with due regard for the provisions in Article 8, paragraph 4 of the Articles of Association of BNG Bank.

REMUNERATION POLICY FOR EMPLOYEESWith effect from 1 January 2017, the primary remuneration of BNG Bank employees consists of the following components, depending on their position.

The fixed component of the remuneration consists of 12 times the monthly salary plus 8% holiday allowance and, where applicable, compensation for a 40-hour working week. Employees, with the exception of managing directors and department heads, receive a 13th-month payment. Increases under the Collective Labour Agreement for the Banking Industry and one-off benefits apply.

Performance-related remuneration was abolished for employees with effect from 1 January 2017. The total variable remuneration for employees (consisting of a profit distribution and a discretionary bonus in exceptional cases) may never exceed 20% of the fixed remuneration. Where this limit would be exceeded, capping will be applied.

FIXED VARIABLE

PERFORMANCE-RELATED REMUNERATION PROFIT DISTRIBUTION

Managing directors Yes No No

Department heads Yes No Yes

Other employees Yes No Yes

REMUNERATION (ARTICLE 450 CRR)

115REMUNERATION (ARTICLE 450 CRR)

All the managing directors/department heads and some specific job holders are designated as Identified Staff. Their variable remuneration by way of profit distribution is subject to a stringent control regime (in this case, the conditional grant of 40% of this remuneration) where it amounts to more than one month’s salary and/or more than EUR 10,000. Employees do not own BNG Bank shares or options and receive no additional remuneration through subsidiaries of the bank.

The provisions of the pension regulations of Stichting Pensioenfonds ABP (average salary system) apply to the fixed remuneration and the profit distribution granted to employees. This fixed remuneration paid is pensionable up to the maximum amount permitted for tax purposes.

The total remuneration granted to ‘Identified Staff’, i.e. individuals with direct influence on the bank’s policy and risks, was EUR 6 million in 2017 (2016: EUR 5 million). The Identified Staff consisted of 31 individuals in 2017 (2016: 30). No employee received remuneration exceeding EUR 1 million in 2017 (2016: none).

REMUNERATION POLICY FOR THE SUPERVISORY BOARDThe remuneration of the Supervisory Board was unanimously approved by the Extraordinary General Meeting of Shareholders in 2016, effective from 1 January 2017. The new policy applies to the period from 1 January 2017 to 31 December 2021, inclusive. This policy is published on bngbank.nl.

The remuneration of the Supervisory Board can rise by the same percentage as the increases under the Collective Labour Agreement from 2017. With effect from 1 January 2017, the Supervisory Board’s committee structure changed. The Market Strategy Committee was dissolved and the Audit & Risk Committee was divided into an Audit Committee and a Risk Committee. The remuneration policy has been amended accordingly. The remuneration policy for the Supervisory Board is directed towards market-compatible remuneration that is irrespective of the company’s result. It also reflects the social nature of the bank, the envisaged quality of the Supervisory Board members, the required availability for the task at hand, and the time required as well as aspects of responsibility and liability. Supervisory Board members do not own BNG Bank shares or options and receive no additional remuneration through subsidiaries of the bank.

The remuneration amounts to EUR 24,300 a year for Supervisory Board members and EUR 35,300 a year for the Chair. Audit Committee and Risk Committee members receive an annual allowance of EUR 6,000 in addition to their remuneration. Members of the Selection and Appointment Committee as well as the Remuneration Committee receive an annual allowance of EUR 1,500 in addition to their remuneration.

Supervisory Board members additionally receive a fixed expense allowance of EUR 1,000 a year. This allowance is increased by EUR 500 for members of the Audit Committee and the Risk Committee, or by EUR 250 for members of the Selection and Appointment Committee/HR Committee as well as the Remuneration Committee.

More details on the remuneration policy, committee, system, criteria and amounts involved are provided in the Annual Report (pp. 73-78, 125-128) as well on the website (e.g. remuneration report).


https://www.bngbank.nl/Pages/Over%20BNG%20Bank/Beloningsbeleid.aspx

116LEVERAGE RATIO (ARTICLE 451 CRR)

Leverage ratio (article 451 CRR)

1 Total assets as per published financial statements

2 Adjustment for entities which are consolidated for accounting

purposes but are outside the scope of regulatory consolidation

3 (Adjustment for fiduciary assets recognised on the balance sheet

pursuant to the applicable accounting framework but excluded

from the leverage ratio exposure measure in accordance with

Article 429(13) of Regulation (EU) No 575/2013 ‘CRR’)

4 Adjustments for derivative financial instruments

5 Adjustments for securities financing transactions ‘SFTs’

6 Adjustment for off-balance sheet items (ie conversion to credit

equivalent amounts of off-balance sheet exposures)

EU-6A (Adjustment for intragroup exposures excluded from the leverage

ratio exposure measure in accordance with Article 429 (7) of

Regulation (EU) No 575/2013)

EU-6B (Adjustment for exposures excluded from the leverage ratio

exposure measure in accordance with Article 429 (14) of

Regulation (EU) No 575/2013)

7 Other adjustments

8 TOTAL LEVERAGE RATIO EXPOSURE

TRANSITIONAL

140,026

–

–

–20,070

–

2,321

–

–

–85

122,192

31/12/2017

FULLY PHASED IN

140,026

–

–

–20,070

–

2,321

–

–

–33

122,244

TABLE LRSUM: SUMMARY RECONCILIATION OF ACCOUNTING ASSETS AND LEVERAGE RATIO EXPOSURES

117

ON-BALANCE SHEET EXPOSURES (EXCLUDING DERIVATIVES AND SFTS)

1 On-balance sheet items (excluding derivatives, SFTs and fiduciary

assets, but including collateral)

2 (Asset amounts deducted in determining Tier 1 capital)

3 TOTAL ON-BALANCE SHEET EXPOSURES (EXCLUDING DERIVATIVES, SFTS AND FIDUCIARY ASSETS) (SUM OF LINES 1 AND 2)

DERIVATIVE EXPOSURES

4 Replacement cost associated with all derivatives transactions

(ie net of eligible cash variation margin)

5 Add-on amounts for PFE associated with all derivatives transactions

(mark-to-market method)

EU-5A Exposure determined under Original Exposure Method

6 Gross-up for derivatives collateral provided where deducted from

the balance sheet assets pursuant to the applicable accounting

framework

7 (Deductions of receivables assets for cash variation margin

provided in derivatives transactions)

8 (Exempted CCP leg of client-cleared trade exposures)

9 Adjusted effective notional amount of written credit derivatives

10 (Adjusted effective notional offsets and add-on deductions for

written credit derivatives)

11 TOTAL DERIVATIVE EXPOSURES (SUM OF LINES 4 TO 10)

SECURITIES FINANCING TRANSACTION EXPOSURES

12 Gross SFT assets (with no recognition of netting), after adjusting

for sales accounting transactions

13 (Netted amounts of cash payables and cash receivables of gross

SFT assets)

14 Counterparty credit risk exposure for SFT assets

EU-14A Derogation for SFTs: Counterparty credit risk exposure in accordance

with Article 429b (4) and 222 of Regulation (EU) No 575/2013

15 Agent transaction exposures

EU-15A (Exempted CCP leg of client-cleared SFT exposure)

16 TOTAL SECURITIES FINANCING TRANSACTION EXPOSURES (SUM OF LINES 12 TO 15A)


CRR LEVERAGE RATIO EXPOSURES

131,036

–85

130,951

1,076

1,710

–

–

–13,866

–

–

–

–11,080

–

–

–

–

–

–

–

31/12/2017


131,036

–33

131,003

1,076

1,710

–

–

–13,866

–

–

–

–11,080

–

–

–

–

–

–

–

TABLE LRCOM: LEVERAGE RATIO COMMON DISCLOSURE

LEVERAGE RATIO (ARTICLE 451 CRR)

118


OTHER OFF-BALANCE SHEET EXPOSURES

17 Off-balance sheet exposures at gross notional amount

18 (Adjustments for conversion to credit equivalent amounts)

19 OTHER OFF-BALANCE SHEET EXPOSURES (SUM OF LINES 17 TO 18)

EXEMPTED EXPOSURES IN ACCORDANCE WITH CRR ARTICLE 429 (7) AND (14) (ON AND OFF BALANCE SHEET)

EU-19A (Exemption of intragroup exposures (solo basis) in accordance

with Article 429(7) of Regulation (EU) No 575/2013 (on and off

balance sheet))

EU-19B (Exposures exempted in accordance with Article 429 (14) of

Regulation (EU) No 575/2013 (on and off balance sheet))

CAPITAL AND TOTAL EXPOSURES

20 Tier 1 capital

21 TOTAL LEVERAGE RATIO EXPOSURES (SUM OF LINES 3, 11, 16, 19, EU-19A AND EU-19B)

LEVERAGE RATIO

22 Leverage ratio

CHOICE ON TRANSITIONAL ARRANGEMENTS AND AMOUNT OF DERECOGNISED FIDUCIARY ITEMS

EU-23 Choice on transitional arrangements for the definition of the

capital measure

EU-24 Amount of derecognised fiduciary items in accordance with

Article 429(11) of Regulation (EU) NO 575/2013


12,789

–10,468

2,320

–

–

4,266

122,192

3.49%

Transitional

31/12/2017


12,789

–10,468

2,320

–

–

4,318

122,244

3.53%

Fully phased in


119

EU-1 Total on-balance sheet exposures (excluding derivatives, SFTs, and

exempted exposures), of which:

EU-2 Trading book exposures

EU-3 Banking book exposures, of which:

EU-4 Covered bonds

EU-5 Exposures treated as sovereigns

EU-6 Exposures to regional governments, MDB, international

organisations and PSE NOT treated as sovereigns

EU-7 Institutions

EU-8 Secured by mortgages of immovable properties

EU-9 Retail exposures

EU-10 Corporate

EU-11 Exposures in default

EU-12 Other exposures (eg equity, securitisations, and other non-credit

obligation assets)

1 Description of the

processes used to

manage the risk of

excessive leverage

2 Description of the

factors that had an

impact on the leverage

Ratio during the period

to which the disclosed

leverage Ratio refers


131,036

–

131,036

1,278

43,374

1,499

14,359

172

–

54,950

33

15,371

Given the fact that a very large part of BNG Bank’s balance sheet consists of 0% credit

risk weighted assets, application of the leverage ratio is much less favourable than the

more highly rated weighted solvency ratio. Thus far, a European minimum requirement for

a leverage ratio of 3% seems most likely to become effective in the near future. For the

time being BNG Bank assumed that it would need to comply with this 3% lower limit from

2018. Partly on account of the hybrid capital issue, the bank’s leverage ratio at the end

of 2016 already reached the required level of 3%. The bank had set itself the goal of

achieving a leverage ratio at year-end 2017 of at least 3.4% (according to fully phased in

calculations). The possible changes in this minimum requirement remain a point of

attention. If the capital planning for the leverage ratio should necessitate a raise in the

near future, the bank would expressly consider a further issue of hybrid capital or further

reducing dividend pay-out. By taking these measures, the bank prevents threats to client

lending due to constrictive leverage ratios.

The obligation to meet a leverage ratio in the future has meant among other things that,

beginning in the 2011 financial year, the dividend was reduced from a payout percentage

of 50% to 25%. This measure was still in place during 2016. In 2017 the proposed dividend

payout ratio was raised to 37.5%. The possibility of attracting hybrid capital that qualifies

as (additional) Tier 1 capital is also part of the migration plan. In 2015 EUR 424 million

hybrid capital was attracted and an additional EUR 309 million was attracted in 2016.

31/12/2017


131,036

–

131,036

1,278

43,374

1,499

14,359

172

–

54,950

33

15,371

TABLE LRSPL: SPLIT-UP OF ON BALANCE SHEET EXPOSURES (EXCLUDING DERIVATIVES, SFTS AND EXEMPTED EXPOSURES)

TABLE LRQUA: FREE FORMAT TEXT BOXES FOR DISCLOSURE ON QUALITATIVE ITEMS


120EXPOSURES IN EQUITIES NOT

INCLUDED IN THE TRADING BOOK

(ARTICLE 447)

Exposures in equities not included in the trading book

(article 447 CCR)

The exposure comprises the shareholdings in BNG Bank’s banking book. The tables below present the various values of the portfolio at year-end 2017 and 2016.

31/12/2017

BALANCE CUMULATIVE RESULTS SHEET VALUE UNREALISED REALISED IN (EXPOSURE) FAIR VALUE RESULTS FINANCIAL YEAR

Financial assets available for sale – – – –

Associates and joint ventures

Associates 3 3 – 1

Joint ventures 44 44 – 7

TOTAL 47 47 – 8

31/12/2016

BALANCE CUMULATIVE RESULTS SHEET VALUE UNREALISED REALISED IN (EXPOSURE) FAIR VALUE RESULTS FINANCIAL YEAR

Financial assets available for sale – – – –

Associates and joint ventures

Associates 3 3 – 1

Joint ventures 43 43 – –7

TOTAL 46 46 – –6

121

BNG Bank has no investments in listed shares. The shares in the Investments in associates and joint ventures balance sheet item concern investments in joint ventures entered into by BNG Gebiedsontwikkeling. The purpose of these partnerships is to develop and allocate land for the construction of homes and industrial estates, together with public authorities, at the bank’s own expense and risk. The shares in associates and the shares in the Financial assets available-for-sale balance sheet item concern investments in private equity exposures in companies that are significant suppliers to the public sector.

The Investments in associates and joint ventures balance sheet item is stated according to the equity method. The Financial assets available-for-sale item is stated at fair value and value movements are recognised in equity, net of taxes. Further information can be found in the Annual Report under ‘Accounting principles for the consolidated financial statements’.

EXPOSURES IN EQUITIES NOT

INCLUDED IN THE TRADING BOOK

(ARTICLE 447)

122EXPOSURE TO SECURITISATION

POSITIONS (ARTICLE 449)

Exposure to securitisation positions (article 449 CCR)

BNG Bank acts primarily as an investor in the most senior tranches of securitisations for the ALM portfolio; these investments in securitisations are part of the banking book. The underlying assets are mostly home mortgages. The bank does not invest in synthetic securitisations or resecuritisations. As well as acting as an investor in securitisations, BNG Bank fulfils a number of additional roles, albeit to a limited extent. These include the role of Issuer Account Bank and the role of Cash Advance Facility Provider in that the bank provides liquidity facilities to finance securitisations. BNG Bank does not act as an originator or sponsor. This means that the bank has not transferred any assets to securitisations and does not support securitised assets.

At year-end 2017 the balance sheet value amounted to EUR 3.3 billion (2016: EUR 3.5 billion) in securitisation positions. The off-balance sheet securitisation commitments at year-end 2017 amounted to EUR 0.2 billion (2016: EUR 0.3 billion) and concerned liquidity facilities. BNG Bank considers the credit risk of these facilities to be virtually zero. The facilities may only be drawn on under strict conditions (e.g. in the event of technical payment problems), and in that case BNG Bank’s claim will have preference over all other claims.

All securitisations in the bank’s portfolio have at least one external rating from S&P, Moody’s, Fitch or DBRS. Any interest rate risks are hedged with derivatives, in conformity with policy. The aforementioned risks are monitored by the Investment Committee. All securitisations are subjected to an impairment test twice a year. As investments are limited to the most senior tranches the liquidity risk for BNG Bank is considered limited as these senior tranches are impacted last if liquidity issues would arise for the underlying securitisation.

31/12/2017 31/12/2016

SECURITISATIONS BROKEN DOWN BY UNDERLYING ASSETS

Securitisations on the balance sheet with underlying assets in:

– Home mortgages 1,060 1,697

– Home mortgages with NHG guarantee 2,197 1,741

– Other 50 50

TOTAL BALANCE SHEET VALUE 3,307 3,488

Off-balance sheet commitments regarding securitisations 233 262

TOTAL SECURITISATION POSITIONS 3,540 3,750

123EXPOSURE TO SECURITISATION

POSITIONS (ARTICLE 449)

31/12/2017 31/12/2016

CAPITAL CAPITAL EXPOSURE REQUIRE EXPOSURE REQUIRE- VALUE MENT VALUE MENT

EXPOSURE VALUE AND CAPITAL REQUIREMENT OF SECURITISATIONS BROKEN DOWN BY RISK WEIGHTING

0% 43 0 32 0

20% 2,389 38 2,555 41

35% 74 2 99 3

50% 736 30 599 24

100% 129 10 243 19

350% 26 7 62 17

1250% 25 – 29 –

TOTAL BALANCE SHEET VALUE 3,422 87 3,619 104

Under CRD IV, BNG Bank applies the Standardised Approach (SA) in calculating risk-weighted exposure values of securitisations in relation to credit risk. Most of the securitisation positions have a 20% weighting. A limited number of securitisations have a 1250% weighting because of the rating. BNG Bank takes advantage of the option to offset these items against the CET1 capital.

124MAPPING OF REGULATORY

REQUIREMENTS

Mapping of regulatory requirements

For the sake of completeness, below table presents an overview of the regulatory criteria with respect to Pillar 3 disclosures and the location where this information is included in this report. Starting point for these regulatory disclosure requirements is Part Eight of the Capital Requirements Directive (CRR). However, the European Banking Authority as well as the European Commission published several additional guidelines or standards that prescribe in more detail how specific information should be disclosed. Most noteworthy in this respect are the following:– EBA/GL/2017/01: Guidelines on LCR disclosure to complement the disclosure of liquidity risk

management – EBA/GL/2016/11: Guidelines on disclosure requirements under Part Eight of Regulation

(EU) NO 575/2013– (EU) 2016/200: Implementing Technical Standards with regard to disclosure of the

leverage ratio– (EU) 2015/1555: Regulatory Technical Standards for the disclosure of information in relation

to the compliance of institutions with the requirement for a countercyclical capital buffer– EBA/GL/2015/22: Guidelines on sound remuneration policies– (EU)1030/2014: Implementing Technical Standards with regard to the disclosure of the values

used to identify global systemically important institutions– EBA/GL/2014/02: Guidelines on disclosure of indicators of global systemic importance– EBA/GL/2014/03: Guidelines on disclosure of encumbered and unencumbered assets– (EU)1423/2013: Implementing Technical Standards with regard to disclosure of own funds

requirements

125

CRR

Article 435

Article 436

DESCRIP-TION

Risk

manage-

ment

objectives

and policies

Scope of

application

EBA/

GL/2016/11

EBA/

GL/2017/01

APPLICABLETABLES OR TEMPLATES

EU OVA

EU CRA

EU CCRA

EU MRA

EU LIQA

EU LIQ1

EU LI1

EU LI2

EU LI3

EU LIA

ADDITIONAL GUIDELINES OR STANDARDS

LOCATION PILLAR 3 REPORT

pp. 8-41

pp. 30-31

pp. 41-48

CLARIFICATION, IF NEEDED

This requires a comprehensive overview on the

risks management objectives and policies. This is

mostly qualitative information for which no specific

format is required. In fact, the risk section of the

Annual Report includes all of the information. For

the sake of completeness, that section is again

included for a large part in this Pillar 3 report as

well. However, quantitative information from the

annual report has been omitted where possible

as EBA regulations now prescribe fixed format

templates which are addressed in other sections

of this report. Furthermore, it should be noted

that quantitative targets on individual risk are not

disclosed due to their confidential nature.

Information regarding the governance arrangements

with respect to the members of the management

and supervisory boards is not included again in this

report. The most up-to-date information on this

can be found on the website of BNG Bank. The

Annual Report includes a comprehensive overview

on this at end 20177.

The CRR does not include a separate article on the

disclosure of liquidity risk, but EBA has issues

guidelines for this under article 435 of the CRR.

Therefore, this information is also included in the

first section of this report.

7 For the Executive Board.

For the Supervisory Board.

The Annual report is available at the website.

MAPPING OF REGULATORY

REQUIREMENTS

Continued

on next page

https://www.bngbank.nl/over-bng-bank/bestuur-en-organisatie/rvb

https://www.bngbank.nl/over-bng-bank/bestuur-en-organisatie/rvc


126

CRR

Article 437

Article 438

Article 439

Article 440

Article 441

DESCRIP-TION

Own funds

Capital

require-

ments

Exposure

to counter-

party

credit risk

Capital

buffer

Indicator of

global

systemic

importance

(EU)1423/

2013

EBA/

GL/2016/11

EBA/

GL/2016/11

(EU)

2015/1555

(EU)

1030/2014


EU OV1

EU CCR1

EU CCR2

EU CCR8

EU CCR5-A

EU CCR5-B



pp. 49-68

pp. 69-75

pp. 101-107

n/a

n/a


BNG Bank own funds consists of share capital

(which is limited to Dutch public authorities by its

articles of association) and hybrid capital. These

instruments are only placed privately with a

limited number of investors. Therefore terms and

conditions for these instruments are not part of

the disclosure as they are only made available to

these parties on the basis of confidentiality.

Qualitative information as described in articles

439(a), (b) and (d) is included in the first section

on risk management objectives and policies, while

article 439(c) is not applicable as BNG Bank has not

identified any wrong way risk. In addition articles

439(g), (h) and (i) are also not applicable as BNG

Bank has no credit derivative hegdes.

The quantitative information from articles 439(e)

and (f) are included in accordance with the

templates provided by EBA.

The geographical distribution of the credit

exposures of BNG Bank is limited and most of

the credit exposures are concentrated in The

Netherlands. Currently, no countercyclical capital

buffer is required for BNG Bank and therefore

no disclosure on this buffer is included.

A geographical breakdown of exposures is part of

the CRB-C template as included in the section on

credit risk.

BNG Bank is not identified as G-SII (Global

Systemically Important Institutions). Therefore,

this article is not applicable for the BNG Bank.


REQUIREMENTS

Continued

on next page

Continuation

of previous

page

127

CRR

Article 442

Article 443

Article 444

Article 445

Article 446

Article 447

DESCRIP-TION

Credit risk

adjustments

Unencum-

bered

assets

Use of

ECAI’s

Exposure of

market risk

Operational

risk

Exposure in

equities not

included in

the trading

book

EBA/GL/

2016/11

EBA/

GL/2014/03

EBA/

GL/2016/11

EBA/

GL/2016/11


EU CRB-A

EU CRB-B

EU CRB-C

EU CRB-D

EU CRB-E

EU CR1-A

EU CR1-B

EU CR1-C

EU CR1-D

EU CR1-E

EU CR2-A

EU CR2-B

EU CRD

EU CR5

EU CCR3

EU MR1



pp. 76-100

pp. 108-111

pp. 20, 99,

104

p. 112

pp. 33-36

pp. 120-121


Qualitative information on the use of ECAI’s is

included in the first section on on risk management

objectives and policies, and specifically in the

subsection on credit risk. The quantitative template

as provided by EBA is part of the section with

templates on credit risk.

As included in table EU OV1 in the section on

capital requirements, BNG Bank applies the

standardized approach for the assessment of own

fund requirements for operational risk.

BNG Bank has a small exposure in equities. An

overview on these exposures is included separately

in this Pillar 3 report.


REQUIREMENTS

Continued

on next page

Continuation

of previous

page

128

CRR

Article 448

Article 449

Article 450

Article 451

Article 452

Article 453

DESCRIP-TION

Exposure to

interest rate

risk on

position not

included in

the trading

book

Exposure

to securi-

tisation

positions

Remunera-

tion policy

Leverage

ratio

Use of IRB

approach to

credit risk

Use of

credit risk

mitigation

technique

EBA/

GL/2015/22

(EU)

2016/200


EU CRC

EU CR3

EU CR4



pp. 23-27

pp. 122-123

pp. 113-115

Annual

Report,

pp. 73-78,

125-128

Website

pp. 116-119

n/a

pp. 16-22,

96-100


An overview on the nature of the interest rate risk

is included in the first qualitative part of this

reports and is specifically addressed in the

subsection on market risk.

BNG Bank has a prudent system of remuneration

which is in line with its simplicity. No variable

components as shares or options are included in

the remuneration and no individuals are being

remunerated EUR 1 million or more. A broad

overview on the policies is included in this report.

Detailed information regarding the remuneration

in the reporting period is included in the Annual

Report. More details on the remuneration policy,

committee, system and criteria are also provided

on the website (e.g. remuneration report).

BNG Bank does not apply the IRB approach.

Qualitative information as described in tables

EU CRC and EU CRD is part of the comprehensive

disclosure in the first section on risk management

objectives and policies. The prescribed quantitative

templates are included separately in this report.


REQUIREMENTS

Continued

on next page

Continuation

of previous

page

https://www.bngbank.nl/Pages/Over%20BNG%20Bank/Beloningsbeleid.aspx

129

CRR

Article 454

Article 455

DESCRIP-TION

Use of the

Advanced

Measure-

ment

Approaches

to Opera-

tional Risk

Use of

internal

market risk

models




n/a

n/a


BNG Bank does not apply the AMA approach to

operational risk.

BNG Bank does not apply internal market risk

models.


REQUIREMENTS

Continuation

of previous

page

BANK

COLOPHON

Editorial: BNG Bank

Design & production: Ron Goos, Rotterdam

BNG Bank

Koninginnegracht 2

P.O. Box 30305

2500 GH The Hague

The Netherlands

Telephone +31 70 3750 750

[email protected]

bngbank.com

Pillar 3 Disclosure report BNG Bank 2017 BNG Bank... · 2018-05-09 · liquidity and operational...

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